1 <Day 24. 2(10.30 a.m.) 3MR RAMPTON: My Lord, before I call Dr Longerich, there are 4three things I think I would like to mention. 5MR JUSTICE GRAY: I want to mention two things to you too. 6MR RAMPTON: Then judge before counsel. 7MR JUSTICE GRAY: All right. One I think I have actually 8discovered the answer to, but can you just confirm that 9the statements which you rely on for saying that Mr Irving 10is a Holocaust denier, are they now collective in K3 and, 11if so, are they going to be refined down, as it were, any 12more or do I take it that K3 is the selection upon which 13you rely. 14MR RAMPTON: My belief is there was an abstract rather like the 15anti-Semitic abstract. It is on Word disk. 16MR JUSTICE GRAY: I actually heard that. If, in due course, 17Mr Irving and I can be supplied with a copy of it, that 18will help a great deal. The other thing is, looking ahead 19a little more, and this is for you, Mr Irving, as well is 20really looking ahead to final speeches, it seems obvious 21that you must both take matters in whatever order you 22think is appropriate, but it seemed to me in this 23particular case it would be quite helpful to have a 24discussion at some stage about a possibly agreed order of 25topics to be covered, because it would help me if I knew 26what you were moving to. If you were to take things in

. P-2

1the same order, you do not have to obviously, but do you 2follow what I am getting at? 3MR RAMPTON: I do. 4MR JUSTICE GRAY: This is quite a difficult case in the sense 5of you cannot take it chronologically and it is quite 6difficult to interrelate some of the issues. 7MR IRVING: Your Lordship is aware that I propose not 8addressing certain issues in my closing speech. 9MR JUSTICE GRAY: That is a matter for you. 10MR IRVING: But I certainly agree that there should be an 11agreed order. 12MR JUSTICE GRAY: I think so. That makes it sound a bit more 13formal than I was really intending, but if we can set 14aside maybe half an hour some time early next week. 15MR RAMPTON: May I say straightaway my present format is to do 16what I call historical falsification first, then because 17it goes with Holocaust denial, Auschwitz, and then what 18I call racism and then finally political associations. 19I will try to order the historical distortions as I did in 20cross-examination, and my witnesses have done more or less 21in the witness box, to do that chronologically. 22MR JUSTICE GRAY: If I can just indicate the problem I have had 23is that the issue of Hitler's knowledge of what was going 24on is quite difficult to accommodate within the structure 25you have just outlined. That is, I think, the area that 26is quite difficult to slot in.

. P-3

1MR RAMPTON: Except to this extent, it does not find a place, 2or not a significant place, in my format because I do not 3believe that it has any relevance except in so far as it 4is on the back of that topic that most of the historical 5distortions ride. 6MR JUSTICE GRAY: Quite, but if you limit -- I am sorry to go 7on about this point; it is quite important to thrash it 8out -- what one might call the historiographical 9criticisms of Mr Irving to the points that are made, 10effectively, by Professor Evans, you slightly miss the 11whole gamut of the continuum, to use a word we have been 12using, of the evidence in relation to that issue. So I 13will just mention that as being a possible difficulty. 14MR RAMPTON: It will have a place in the file which -- your 15Lordship I hope now has, which we have finished, I am 16afraid -- that was the other thing I was going to say and 17apologise -- a bit late yesterday. It contains what we 18think are the core history documents and that, obviously, 19bears on the Hitler knowledge question. 20 There will be in what I have to say a certain 21amount relating to Hitler's knowledge, Hitler's authority, 22Hitler's orders, if you like, but only in so far as the 23evidence leads to the conclusion reached by Sir John 24Keegan, for example, that the idea that he did not know 25defies reason. 26MR JUSTICE GRAY: We will spend a bit more time on perhaps

. P-4

1discussing that. 2MR RAMPTON: One other thing: as to that Hitler knowledge 3question, what Miss Rogers has done is to prepare a 4reference, chronological reference document, for what are 5the most important -- it is not exhaustive -- Hitler 6statements, in our submission. Can I pass that up? 7MR JUSTICE GRAY: Where do you want me to put it? Have you had 8this, Mr Irving? 9MR IRVING: No, I have not. 10MR JUSTICE GRAY: Is there a copy for Mr Irving? 11MR RAMPTON: N1, I think it is. It is the new file anyway and 12it is ---- 13MR JUSTICE GRAY: It is called N1, thank you. 14MR RAMPTON: There is one other thing I should say. Your 15Lordship asked for a note on the admissibility of expert 16evidence in written form. I have done a note on that. It 17will be ready by 2 o'clock. It is being typed. 18MR JUSTICE GRAY: Obviously, Mr Irving should have a chance to 19look at it before we have any submissions there are going 20to be about it. 21MR RAMPTON: I will attach to it, there are some pieces of 22paper showing what the statutes and the rules say. 23MR JUSTICE GRAY: Thank you very much. Mr Irving? 24MR IRVING: My Lord, the only thing I would wish to add to that 25is a request that there should be one clear day before the 26submission of closing speeches.

. P-5

1MR JUSTICE GRAY: There will be more than that, I think. 2MR RAMPTON: I need much more than one day. 3MR IRVING: The words "at least" was in square brackets before 4"one clear". 5MR JUSTICE GRAY: Yes, I do not think we want to have too long 6because I am not sure that speeches are necessarily going 7to need to go through everything, as it were, in detail; 8it is more a question of references, I think, in a way. 9MR RAMPTON: I thought what I would do is a shortish sort of 10summary to read out in court with a file, which I would 11not read in court, of where necessary detailed reasoning 12and references just for your Lordship and, of course, 13eventually the public too. 14MR JUSTICE GRAY: My feeling is it will be three plus days. 15Does that sound sensible to you? 16MR IRVING: That will suit my needs, yes. 17MR JUSTICE GRAY: That is everything you want to say? 18MR IRVING: I think so, yes, my Lord. 19MR JUSTICE GRAY: So it is Dr Longerich, gentlemen? 20Mr Rampton, I have just been told there is an interpreter 21as well which rather surprises me because I thought 22Dr Longerich was giving expert evidence about the 23translation of German words into English. 24MR RAMPTON: Yes. His English is very good, but there are 25times when his thought processes on a sophisticated or 26difficult question are in German, and when he feels

. P-6

1uncertain that he may get quite the right nuance or 2emphasis in English, and it is only for that. It is not 3going to be a continuous process. 4MR JUSTICE GRAY: Good, 5(Interpreter sworn) 6< DR PETER LONGERICH, sworn. 7< Examined by MR RAMPTON, QC. 8MR JUSTICE GRAY: Dr Longerich, do sit down if you would 9rather? 10MR RAMPTON: Dr Longerich, are your full names Heinz Peter 11Longerich? 12A.
[Dr Heinz Peter Longerich]
Peter Longerich, yes. 13Q.
[Mr Rampton]
Peter Longerich, sorry. Have you written a report in two 14parts for the purposes of this case? 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Rampton]
Are you satisfied, so far as can you be, that the 17statements of fact contained in those reports are true? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Rampton]
And that, so far as those reports contain expressions of 20opinion, those opinions are fair and accurate? 21A.
[Dr Heinz Peter Longerich]
That is correct. 22Q.
[Mr Rampton]
You speak quite softly. I am a long way away at least. 23Can you try to speak up? 24A.
[Dr Heinz Peter Longerich]
I will do my best. 25Q.
[Mr Rampton]
Thank you very much. Please remain there to be 26cross-examined.

. P-7

1< Cross-examined by MR IRVING. 2Q.
[Mr Irving]
Good morning, Dr Longerich. 3A.
[Dr Heinz Peter Longerich]
Good morning. 4Q.
[Mr Irving]
Just to clarify one matter. Should I address you as 5"Professor" or a "Doctor"? 6A.
[Dr Heinz Peter Longerich]
Dr Longerich. 7Q.
[Mr Irving]
Thank you very much. My Lord, just by way of diversion, 8I provided your Lordship the two documents of which you 9asked translations. This is nothing to do with 10Dr Longerich, but you asked this and I should have drawn 11your attention to this. There is the translation of the 12Party court in 1939. 13MR JUSTICE GRAY: I remember, the Bericht. 14MR IRVING: It is the final paragraph which is in endless 15lawyer language. That is the official American 16translation of it. 17MR JUSTICE GRAY: I will tell you what, let us come back to 18this and then we will at the same time work out where to 19put these documents. 20MR IRVING: Precisely, my Lord, and also there is a small 21bundle of documents which look like this beginning with 22some Gothic script on the front cover. 23MR JUSTICE GRAY: With "ausrotten". 24MR IRVING: With "ausrotten", yes. 25 My Lord, just so you know where we are going 26today, I will advise your Lordship that I intend to deal

. P-8

1today largely, and certainly this morning, with this 2witness's statement on the meaning of words, this late 3arrival, which I thought would be a useful way to kick off 4and then we will turn to this formal reports. 5 Before we do that, I just want to address one or 6two matters concerning, through the witness, conduct of 7the case and his credentials. Professor Longerich ---- 8A.
[Dr Heinz Peter Longerich]
Dr Longerich. 9Q.
[Mr Irving]
--- Dr Longerich, I am sorry. You work for a number of 10years at the Institut fur Zeitgeschichte in Munich, did 11you not? 12A.
[Dr Heinz Peter Longerich]
This is correct, yes. 13Q.
[Mr Irving]
You have to say yes clearly. A nodding will not do. You 14have to say yes otherwise ---- 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
--- the microphone does not hear it. How many years did 17you work at the Institute of History in Munich? 18A.
[Dr Heinz Peter Longerich]
From 1983 to 1989. 19Q.
[Mr Irving]
1983 to 1989. That was, what, five years then? 20A.
[Dr Heinz Peter Longerich]
About five years -- a little bit more. 21Q.
[Mr Irving]
About five or six years. Did you have a special subject 22you were working on there? 23A.
[Dr Heinz Peter Longerich]
I worked on a project called condition of the files of the 24Party Chancellory. 25Q.
[Mr Irving]
The Martin Bormann files, the files of the Party 26Chancellory?

. P-9

1A.
[Dr Heinz Peter Longerich]
Yes I edited the second part of this edition. 2Q.
[Mr Irving]
Yes. The Party Chancellory files no longer existed and 3they were reconstituted, is that right? 4A.
[Dr Heinz Peter Longerich]
It is an attempt to reconstruct the lost files of the 5Party Chancellory, so I edited about 80,000 pages of these 6documents. 7Q.
[Mr Irving]
A spectacular task. So that gives you a very good 8overview over the whole of the domestic life of Nazi 9Germany? 10A.
[Dr Heinz Peter Longerich]
I think it gave me a good insight into the day to day 11operation of the bureaucracy in the Nazi State. 12Q.
[Mr Irving]
And into the kind of language they used? 13A.
[Dr Heinz Peter Longerich]
Yes, of course. 14Q.
[Mr Irving]
And into the hierarchy and the various rivalries and 15disputes? 16A.
[Dr Heinz Peter Longerich]
Exactly. 17Q.
[Mr Irving]
Was friction between the top Nazis a major element of the 18Third Reich? 19A.
[Dr Heinz Peter Longerich]
Absolutely. 20Q.
[Mr Irving]
[German] -- in other words ---- 21A.
[Dr Heinz Peter Longerich]
Yes. 22Q.
[Mr Irving]
--- jealousies between the different ministries and 23agencies? 24A.
[Dr Heinz Peter Longerich]
In-fighting and these things, yes. 25Q.
[Mr Irving]
Would you, from your knowledge of other governments, think 26it was more or less than other governments around that

. P-10

1time, British government or the American government, or 2was it something extraordinary, the degree of ---- 3A.
[Dr Heinz Peter Longerich]
I made point in the book I wrote on the Party Chancellery 4that I think this exceeded the normal of in-fighting you 5find in all governments. It is a special case here. 6Q.
[Mr Irving]
Yes. When you worked in the Institute of History, who was 7the director at that time? Was it still Martin Broszat? 8A.
[Dr Heinz Peter Longerich]
At this time it was Martin Broszat until his death in 91989. 10Q.
[Mr Irving]
He had a very great reputation, did he not, and he is 11still greatly admired by German historians? 12A.
[Dr Heinz Peter Longerich]
Yes, I think so. 13Q.
[Mr Irving]
Were you familiar with all the collections of documents in 14the Institute files? Did you work in the archives at all? 15A.
[Dr Heinz Peter Longerich]
Not all the files. I mean, the Institute has an enormous 16collection of files, but I know some of them. 17Q.
[Mr Irving]
Yes. Was Dr Hoff still there, Anton Hoff, the archivist? 18A.
[Dr Heinz Peter Longerich]
No, I think he died in 1883. 19Q.
[Mr Irving]
1983? 20A.
[Dr Heinz Peter Longerich]
1983, sorry. 21Q.
[Mr Irving]
Just before you came? 22A.
[Dr Heinz Peter Longerich]
Yes. 23Q.
[Mr Irving]
It is a very friendly atmosphere there at the archives, at 24the institute? 25A.
[Dr Heinz Peter Longerich]
I think they were friendly to me. I do not know ---- 26Q.
[Mr Irving]
They are very co-operative, are they not? They do not

. P-11

1hold things back very much apart from own private 2collections? 3A.
[Dr Heinz Peter Longerich]
I cannot make such a general statement. 4Q.
[Mr Irving]
In fact, you probably had quite a lowly position there, 5did you not? You were a newcomer and you were working in 6the Institute? 7A.
[Dr Heinz Peter Longerich]
I have no difficulties in actually getting access to the 8collection but I cannot make a general statement on that. 9Q.
[Mr Irving]
Did you ever take the opportunity to look at what is now 10ED 100, the collection of my documents which is in the 11Institute? 12A.
[Dr Heinz Peter Longerich]
I think I have seen some of the ED 100 files, but I cannot 13say that I have a complete overview. 14Q.
[Mr Irving]
Yes. 15A.
[Dr Heinz Peter Longerich]
I have seen some of them yes, but at the moment I cannot 16recall every document I have seen in the Institute. 17Q.
[Mr Irving]
I am just going to give you a list of names of collections 18of diaries. I am sorry, you have a copy of this already. 19I ought to give a copy to his Lordship, perhaps. (Same 20handed) just on the back of that there is a blue column 21called Hitler's People. Do you have that if you turn it 22over? There is a list of names of diaries that I used 23when I wrote my book Hitler's War, which are now in the 24archives. I have added to those since then but I just 25pick out a few names. Canaris: Would that be a valuable 26source?

. P-12

1A.
[Dr Heinz Peter Longerich]
At the moment I cannot recall the Canaris diaries. I am 2not able to comment on every item, but I think some of 3them are of course important. 4Q.
[Mr Irving]
Some are more important and some are less important? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
Dr Longerich, I am not trying to trick you. I am just at 7this stage trying establish -- I will give a little 8warning if I am going to try and trick you. 9MR JUSTICE GRAY: Mr Irving, do I get anything more from than 10that -- is this the new edition that is coming out 11shortly. 12MR IRVING: No, this is the second edition, my Lord, but I just 13wanted to comment on the fact I wondered whether he had 14taken the trouble to look at these very important 15collections of diaries that are in my collection, either 16for his own work or in the expert report. 17MR JUSTICE GRAY: Can you put it as a single question rather 18than the whole lot? 19MR IRVING: Yes. Did you use the diary of Walter Havel? 20A.
[Dr Heinz Peter Longerich]
I looked at the transcripts. I think it is in England, is 21it not, the original? I looked at the transcripts at one 22stage but not for the Party Chancellery. I think I looked 23at the Bormann, it is more a calendar. 24Q.
[Mr Irving]
The calendar? 25A.
[Dr Heinz Peter Longerich]
Yes. 26Q.
[Mr Irving]
Which I have now provided to the Defendants. The Walter

. P-13

1Havel diary does contain one of these episodes July 1941, 2does it not, where Hitler describes the Jews as a 3bacillus? 4A.
[Dr Heinz Peter Longerich]
I cannot recall this particular passage, I am afraid. 5Q.
[Mr Irving]
When you drew up this glossary of meanings of words, 6which, I must say, I find very useful indeed, and this 7goes purely to the conduct of the case, when did you start 8writing that approximately? 9A.
[Dr Heinz Peter Longerich]
I think it was in December last year. 10Q.
[Mr Irving]
In December last year? 11A.
[Dr Heinz Peter Longerich]
Yes, I tried to use the Christmas holiday to do it. 12Q.
[Mr Irving]
When did you complete it? 13A.
[Dr Heinz Peter Longerich]
I think it was actually in January think. 14Q.
[Mr Irving]
You completed it in January? 15A.
[Dr Heinz Peter Longerich]
Yes, January I think. 16Q.
[Mr Irving]
Yes. When were you asked to do it by the instructing 17solicitors in this case? 18A.
[Dr Heinz Peter Longerich]
I think they wrote me an e-mail. I think it was in 19November, but I could not start immediately to work on it 20because I had other obligations. So I am sure I started 21to work on it at the end of the Christmas holidays. 22Q.
[Mr Irving]
You got a letter of instruction? 23A.
[Dr Heinz Peter Longerich]
I think, as far as I recall this, I got an e-mail. 24Q.
[Mr Irving]
Yes. So you got an e-mail sometime in November, you began 25writing in December and you completed it in January? 26A.
[Dr Heinz Peter Longerich]
Yes, that is right.

. P-14

1Q.
[Mr Irving]
Any idea when in January you completed it? 2A.
[Dr Heinz Peter Longerich]
I think it was more through the end of January, probably 3on the first days of February, I cannot recall. 4MR RAMPTON: I can help, I think, because now it comes out of 5Dr Longerich's hands, as it were. It came in its first 6version in German, which, since I was the person who 7requested it, I think in November is right, maybe even 8October, and was useless to me. So it had to be 9translated. It came back and the translation was, to say 10the least, unsatisfactory. Then it had it go back again, 11and what we now have emerged in the course of the last few 12days. 13MR IRVING: Yes. 14MR JUSTICE GRAY: Mr Irving I am not unsympathetic to the fact 15that you are having to deal with this at pretty short 16notice because it came to you very, very late in the day. 17MR IRVING: Of course I accept Mr Rampton's explanation but it 18was delivered to me on Friday evening and, if it turns out 19he completed it in January, I would have wanted to know 20what the reason for the delay was. 21MR JUSTICE GRAY: If you want to say you want Dr Longerich to 22come back at some later stage because you want to ask some 23further questions, you would be pushing at an open door. 24MR IRVING: I fully accept Mr Rampton's explanation about 25translation difficulties. 26 During your professional career, Dr Longerich,

. P-15

1as you say in your curriculum vitae on page 3 of your 2report, you have received research grants from the German 3Historical Institute in London, and from the Deutsche 4Forschungsgemeinschaft and also from Yad Vashem? 5A.
[Dr Heinz Peter Longerich]
Yes, that is true. 6Q.
[Mr Irving]
Are you still in debt to Yad Vashem in any way? 7A.
[Dr Heinz Peter Longerich]
I started to work on the project. The project has not yet 8been completed. The relationship, there is no contract 9between us and in this sense, it is not a book contract or 10something like that, but I still have to complete this 11project we started a couple of years ago. 12Q.
[Mr Irving]
I do not want to know any figures or quantum. Does this 13mean to say they paid you in advance for something and you 14are still working on it? 15A.
[Dr Heinz Peter Longerich]
No. They paid me for ten months actually. It enabled me 16to live in Israel for ten months. 17Q.
[Mr Irving]
As you say in this ---- 18MR JUSTICE GRAY: What will you be doing for them? What will 19you be researching? 20A.
[Dr Heinz Peter Longerich]
We started to work on a project, a documentation about the 21deportation of the Jews from Germany to Minsk and Riga and 22I had a partner there. We started to collect the 23documents, but unfortunately the work has not been 24completed yet. It is actually a major project and has not 25been completed yet. 26MR IRVING: The Eastern European archives have turned out to be

. P-16

1particularly fruitful, is that right? 2A.
[Dr Heinz Peter Longerich]
Absolutely, yes. 3Q.
[Mr Irving]
Is it to be regarded as a great tragedy they have only 4recently in the last ten or 15 years become available to 5historians? Is that right? 6A.
[Dr Heinz Peter Longerich]
I cannot comment whether it is a tragedy. It is a fact 7that it has become available in the last years. 8Q.
[Mr Irving]
They were not available at the time I wrote my first 9edition of the Hitler biography in the 1960s? 10A.
[Dr Heinz Peter Longerich]
With some exceptions. It was always possible to get some 11of the documents out of the archives. For instance, there 12is a large collection of documents in the German Central 13Agency for the Prosecution of Nazi Crimes. They actually 14managed to get a large collection from this material in 15the 1960s. There is also a large collection in the 16Bundesarchives archive and individual researchers had the 17chance to see not the whole archives but some of the 18documents. 19Q.
[Mr Irving]
If I can just dwell briefly on the files in the 20Zentralestelle, which is presumably the ZST source? 21A.
[Dr Heinz Peter Longerich]
Absolutely, yes. 22Q.
[Mr Irving]
You did not identify that in your report, did you? 23A.
[Dr Heinz Peter Longerich]
I think there is a list of abbreviations and it should be 24there. 25Q.
[Mr Irving]
The documents provided by the Eastern European archives to 26the German Zentralestelle, which is a prosecuting archive

. P-17

1-- could I put it like that? 2A.
[Dr Heinz Peter Longerich]
It is the house archive of this agency. They have their 3own library and their own archival collection. 4Q.
[Mr Irving]
At Ludwigsburg? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
Is it specifically collected for the purpose of carrying 7out prosecutions of German and other citizens for war 8crimes? 9A.
[Dr Heinz Peter Longerich]
That is the main purpose of the whole institution and of 10course mainly some historical background. 11Q.
[Mr Irving]
They have very valuable collections of documents there, do 12they not? 13A.
[Dr Heinz Peter Longerich]
They have a very good collection, yes. 14Q.
[Mr Irving]
That is where Dr Goldhart worked, for example? 15MR JUSTICE GRAY: Mr Irving, do you think we should move on 16from the archives? 17MR IRVING: I just want to ask one question which makes the 18point clear, my Lord. Is it apparent to you that, if an 19archive has been collected for the purposes of 20prosecution, it is less likely to include defence 21material, if I can put it like that? 22A.
[Dr Heinz Peter Longerich]
Well, you can use this material in different ways. I do 23not say that they had a complete set of documents from the 24Russian archives. It is certainly a selection. I did not 25select it. I do not know who selected it and who made the 26decision about this, so I should be very careful to make a

. P-18

1comment on that. 2Q.
[Mr Irving]
You would always bear in mind using such archives that you 3are only seeing one side of the picture and not 4necessarily the other side? 5A.
[Dr Heinz Peter Longerich]
I think it is difficult to say because they were 6interested. They did a lot of work in this Zentralestelle 7during the 1950s and 60s, and they actually had historical 8expertise there because they actually worked on the 9historical background. I would not say that they were 10only interested in this aspect of prosecution. I think 11they had to collect the historical expertise which was not 12available at this time and could not be provided by 13historians. So I would be cautious to make such a 14statement about this collection. 15Q.
[Mr Irving]
I see on page 5 of your report that you are an expert, or 16you have written about the Wannsee conference? 17A.
[Dr Heinz Peter Longerich]
Yes, I gave the annual lecture in 1998 at the Haus of the 18Wannsee conference and this published as a booklet. 19Q.
[Mr Irving]
I do not want a lengthy answer at this time. I just want 20a brief overview. Is it right that opinions differ as to 21the importance of the Wannsee conference in the history of 22the Final Solution? 23A.
[Dr Heinz Peter Longerich]
I do not think, generally speaking, the short answer, 24I would not say that there is so much difference about the 25significance of the Wannsee conference. It was basically 26a conference on the implementation of what is called the

. P-19

1Final Solution. I think a statement like this could be 2accepted by most of the historians. Of course, if you go 3into the interpretation of the text, you will find 4differences. 5Q.
[Mr Irving]
Opinions differ? 6A.
[Dr Heinz Peter Longerich]
Opinions differ among historians. 7Q.
[Mr Irving]
Yehuda Bauer has said one thing, Eberhard Jaeckel has said 8another, and so on? 9A.
[Dr Heinz Peter Longerich]
I would be very careful to make a general comment. One 10could look at the writings of Yehuda Bauer and Eberhard 11Jaeckel and then I am prepared to comment on it. 12Q.
[Mr Irving]
My Lord, the next question is purely pre-emptive in case 13another matter comes up. This is still on that page, 14three paragraphs from the bottom. You edited something 15called "Was ist des Deutschen Vaterland", a book on German 16unity? 17A.
[Dr Heinz Peter Longerich]
Yes. That is a collection of documents. Actually 18I issued this in 1990 when this was actually called, as 19you see here, documents about the question of German unity 20so that, when the book came out, the question was solved. 21Q.
[Mr Irving]
Would you tell the court please, during the 1960s, 1970s, 22and 1980s, or certainly during the 1960s and 1970s, what 23was the official designation in west German circles of the 24Soviet zone or the German Democratic Republic? 25A.
[Dr Heinz Peter Longerich]
The official name? 26Q.
[Mr Irving]
The official name, Sprachledlung.

. P-20

1A.
[Dr Heinz Peter Longerich]
I do not think there was a Sprachledlung but I think in 2the 1950s the generally preferred term was Soviet zone of 3Occupation. This changed, then in the 1960s, at the end 4of the 1960s, when it became more common to speak of the 5German Democratic Republic, but I am certainly not an 6expert on, you know, on this issue ---- 7Q.
[Mr Irving]
Have you ever heard of the word Middle Deutschland. 8A.
[Dr Heinz Peter Longerich]
Yes, of course. 9Q.
[Mr Irving]
Was that also an official designation? 10A.
[Dr Heinz Peter Longerich]
This was also common, yes. 11Q.
[Mr Irving]
No kind of revanches sentiment was attached to that word? 12A.
[Dr Heinz Peter Longerich]
I would be very careful to make such a general statement. 13It is a complex issue. 14Q.
[Mr Irving]
Professor Longerich, I think I can say quite evidently 15that you harbour no personal dislike or animosity towards 16me at this stage? 17MR JUSTICE GRAY: No, I am sure not. Mr Irving, shall we move 18towards one of the substantive questions that you are 19going to have to ask about? Let us move on, in other 20words. 21MR IRVING: On page 8, three paragraphs from the bottom, you 22lecture the German Historical Institute ---- 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
--- on the policy of destruction, vernichtung? 25A.
[Dr Heinz Peter Longerich]
Yes, that is the title you prefer. I cannot recall the 26exact English title of this lecture.

. P-21

1Q.
[Mr Irving]
Politik der Vernichtung. Was I present in the audience on 2that occasion? 3A.
[Dr Heinz Peter Longerich]
I think I remember you, yes. 4Q.
[Mr Irving]
Did you invite questions at the end of that function? 5A.
[Dr Heinz Peter Longerich]
The Director of the Institute invited question, yes. 6Q.
[Mr Irving]
Did I ask a question? 7A.
[Dr Heinz Peter Longerich]
Yes, you asked a question. 8Q.
[Mr Irving]
What did the Director of the Institute say? 9A.
[Dr Heinz Peter Longerich]
The Director said, "Dr Longerich does not want to answer 10your question". 11Q.
[Mr Irving]
He said, "Dr Longerich has informed me in advance he will 12not answer any questions from Mr David Irving"? 13A.
[Dr Heinz Peter Longerich]
That is correct, yes. 14Q.
[Mr Irving]
Thank you very much. Was there any specific reason for 15your refusal? 16A.
[Dr Heinz Peter Longerich]
I think there was a discussion in the Institute whether 17you should be actually asked to leave the building, and, 18well, at this stage I actually know, I actually knew that 19I would be called into the witness stand here, and 20I thought it was better not to answer this question, not 21to have a kind rehearsal of this. 22MR JUSTICE GRAY: Sorry, you did or you did not know you were 23going to be a witness? 24A.
[Dr Heinz Peter Longerich]
I was quite aware, I think, that I would be. 25MR JUSTICE GRAY: Oh, you were, even back in 1988? 26A.
[Dr Heinz Peter Longerich]
Yes.

. P-22

1MR IRVING: Did you state that at the time? 2A.
[Dr Heinz Peter Longerich]
Pardon? 3Q.
[Mr Irving]
Did you state that to the Chairman at the time as the 4reason why? 5A.
[Dr Heinz Peter Longerich]
No. I did not give a reason. 6Q.
[Mr Irving]
What was the question I asked? Do you remember? What 7document was I asking about? 8A.
[Dr Heinz Peter Longerich]
I think you were asking about the Schlegelberger, what you 9called the Schlegelberger document. 10Q.
[Mr Irving]
I read out the Schlegelberger document and invited you to 11reconcile it with what you had said in your lecture? 12A.
[Dr Heinz Peter Longerich]
I think this was the moment when you called me a 13"coward"? Isn't this this incident? 14Q.
[Mr Irving]
That is right, yes. 15A.
[Dr Heinz Peter Longerich]
Yes. I can recall this, yes. 16Q.
[Mr Irving]
Just a brief answer this time, do you consider the 17Schlegelberger document to be a key document in the 18history of the Final Solution? 19A.
[Dr Heinz Peter Longerich]
No, absolutely not. 20Q.
[Mr Irving]
Totally unimportant? 21A.
[Dr Heinz Peter Longerich]
It is unimportant, yes. 22Q.
[Mr Irving]
Have you mentioned it in any of your books? 23A.
[Dr Heinz Peter Longerich]
No, I do not think so. 24Q.
[Mr Irving]
A book, in other words, a document which says the Fuhrer 25has asked repeatedly for the solution of the Jewish 26problem postponed until the war is over, in your view, was

. P-23

1unimportant? 2A.
[Dr Heinz Peter Longerich]
Well, that is your interpretation of the document. 3Q.
[Mr Irving]
I am saying what it says. 4A.
[Dr Heinz Peter Longerich]
Yes, it is third-hand evidence. It is an undated 5document. We do not know who actually wrote the 6document. It is third-hand evidence. It is about Lammers 7who said that somewhere in the past Hitler had said 8something to him about the solution, not the Final 9Solution, of the Jewish question. I think we will come to 10the document later in more detail, but I think I could not 11see this and I cannot see this as a major document, let us 12say, for the interpretation of the Holocaust. 13Q.
[Mr Irving]
What would have prevented you saying this to what was 14obviously a friendly audience at the German Institute 15on ---- 16MR JUSTICE GRAY: He has given his answer. You may not accept 17it, but he felt inhibited by the fact he had been asked to 18give expert evidence. 19A.
[Dr Heinz Peter Longerich]
I should mention that I do not want to find myself on 20Mr Irving's website with my answer. I felt myself ten 21with the full comment, you know, of my behaviour and 22I know that Mr Irving was doing these things, and I do not 23want to get engaged in this kind of argument or debate, so 24I prefer to be silent. 25Q.
[Mr Irving]
You prefer there not to be a debate, is that right? 26A.
[Dr Heinz Peter Longerich]
Pardon?

. P-24

1Q.
[Mr Irving]
You prefer there not to be any debate on things like this? 2A.
[Dr Heinz Peter Longerich]
No, I do not prefer to be involved in this kind of debate 3that you, you know, should be more specific, not to be 4with my comment. I do not want to find me on your web 5page which is what I said during this discussion or during 6this lecture. This was the second reason. 7Q.
[Mr Irving]
We are now going to go to the meaning of words, Professor 8Longerich. Again this is perfectly straightforward 9questioning and answering. There are no concealed tricks 10involved here. Would you agree that a lot of the words 11that you have put in your list quite clearly show an 12intention, a homicidal intent, if I can put it like that? 13A lot of the euphemisms used by the Nazis? 14A.
[Dr Heinz Peter Longerich]
Yes, I think that is true. 15Q.
[Mr Irving]
A lot of them are ambiguous? 16A.
[Dr Heinz Peter Longerich]
They are in the way they were used they are. They are 17sometimes ambiguous, yes. 18Q.
[Mr Irving]
It is really a bit of a minefield, is it not? 19A.
[Dr Heinz Peter Longerich]
Well, I think, I cannot speak about minefields. I think 20what an historian has to do, he has to look at each 21document and has to look at the context and then try to 22reconstruct from the context what actually the meaning of 23this, of this passage might be. 24Q.
[Mr Irving]
But is not the danger there that you then come back using 25our pre-Ori methods, that you extrapolate backwards from 26your knowledge and assign a meaning to the word rather

. P-25

1than using the word to help you itself? 2A.
[Dr Heinz Peter Longerich]
That is the problem with all interpretations. You have to 3come back. Of course, you cannot analyse the word 4completely, you know, outside. You have to look at the 5meaning of the word, but always in a historical context. 6I am not a linguist, so I prefer to actually, as I said, 7to look at the context and to ---- 8Q.
[Mr Irving]
You speak English very well, Dr Longerich, if I may say 9so, and I think we are all very impressed by that and I am 10certainly impressed by the arguments you have put forward 11in your glossary. Would you agree also that the same word 12can have different meanings when uttered by different 13people? 14A.
[Dr Heinz Peter Longerich]
Yes. That is exactly why I think it is important always 15to look at the context because, as you rightly said, the 16same word could have different meanings in different 17contexts. 18Q.
[Mr Irving]
The same word can also have a different meaning depending 19on when it is uttered? 20A.
[Dr Heinz Peter Longerich]
Exactly. 21Q.
[Mr Irving]
Even by the same person? 22A.
[Dr Heinz Peter Longerich]
Exactly. 23Q.
[Mr Irving]
Or in what circumstances it is uttered? 24A.
[Dr Heinz Peter Longerich]
That is what I call the context. 25Q.
[Mr Irving]
The only two words I am really concerned with (but we will 26certainly look at the other words in your glossary) are

. P-26

1the words "vernichtung" which is destruction or 2annihilation? 3A.
[Dr Heinz Peter Longerich]
I said, I translate it as, I could accept this 4translation, but I also think in our context, I said 5probably the translation "extermination" is the better one 6or the more appropriate one. 7Q.
[Mr Irving]
Yes, well, "extermination" is a possible one, but you will 8appreciate it is not always proper to go for the third or 9fourth meaning of a word? 10A.
[Dr Heinz Peter Longerich]
I do not know what you mean by "the third or fourth 11meaning". If you mean the use of dictionaries, I think 12that is a rather mechanical way, you know, at looking at 13dictionaries. Of course, a dictionary offers various 14meanings and you have to probably go to the third or 15fourth meaning if the context suggested that, the context 16in which the document stands. So I do not think a 17translator or an historian would always in a mechanical 18way take the first meaning in the dictionary. 19Q.
[Mr Irving]
Here is a 1935 dictionary that says -- I will just check 20it -- "vernichtung" has only two meanings and that is 21"annihilate; destroy"? 22A.
[Dr Heinz Peter Longerich]
This looks rather small, your dictionary, if I may say so, 23and you find other dictionaries -- actually, I do not 24think that. 25Q.
[Mr Irving]
I have any number of other dictionaries going back over 26the years.

. P-27

1A.
[Dr Heinz Peter Longerich]
We can go, if you want, to the dictionaries. 2MR JUSTICE GRAY: I think what the witness is saying is you can 3swap dictionary definitions until the cows come home and 4no-one is at the end of it any the wiser. 5MR IRVING: The other word I want to look at is "ausrotten" and 6I am going to ask you very quickly, Dr Longerich, to take 7this little bundle of documents which is on the left-hand 8side there which I just gave you. 9A.
[Dr Heinz Peter Longerich]
I just see this for the first time, I have to say. 10Q.
[Mr Irving]
Is that the little bundle there? 11A.
[Dr Heinz Peter Longerich]
Yes. 12Q.
[Mr Irving]
Yes. I have given it to you for the first time because 13perhaps I can ask an interim question. When you compiled 14your glossary, Dr Longerich, did you have before you a 15number of documents from a dossier on the word "ausrotten" 16that had been provided by the Defence solicitors? 17A.
[Dr Heinz Peter Longerich]
Sorry, a glossary of terms of what the word ---- 18Q.
[Mr Irving]
When you wrote your glossary ---- 19A.
[Dr Heinz Peter Longerich]
Yes. 20Q.
[Mr Irving]
--- did you before you a number of documents provided to 21you by the Defence solicitors? 22A.
[Dr Heinz Peter Longerich]
No, I cannot actually -- I cannot recall this. I wrote 23this in Munich but, of course, it was holidays and when 24I did this, I did not have anything in front of me. 25Q.
[Mr Irving]
Very well. The first page, page 1 -- I am looking at the 26big numbers at the bottom -- the ausrottung des Prostesten

. P-28

1tismus? 2A.
[Dr Heinz Peter Longerich]
Your bundle, yes. 3Q.
[Mr Irving]
It is my little bundle, yes. This is 1900 ---- 4A.
[Dr Heinz Peter Longerich]
Yes. 5Q.
[Mr Irving]
-- published by some church body, and it is about the 6ausrotten des Prostesten tismus in Salzburg? 7A.
[Dr Heinz Peter Longerich]
Yes. 8Q.
[Mr Irving]
Obviously, they are not talking about liquidating all the 9Protestants, are they? 10A.
[Dr Heinz Peter Longerich]
I do not know, I mean, you know, in Germany in the 17th 11century, for instance, they had what they called religious 12wars and many people were actually ausgerot for religious 13reasons. So if you give me a chance to find out whether 14this is about the 30 year war. 15MR JUSTICE GRAY: It appears to be dated 1900. I do not know 16whether the Gothic script means it is older than that. 17A.
[Dr Heinz Peter Longerich]
It is written 1900, but is it not historical subject? 18MR JUSTICE GRAY: Mr Irving, if I may say so, I do not think we 19will get very much help out of that. 20A.
[Dr Heinz Peter Longerich]
I see. It is about the church history of the 18th 21century. 22Q.
[Mr Irving]
I am looking just at the use of the word, my Lord, and 23suggesting strongly that at this time they were not -- it 24is in close parallel to the phrase the ausrotten des 25Judentums? 26MR JUSTICE GRAY: Yes. I follow the point you are making, but

. P-29

1can one not put it this way? Do you accept or not, I do 2not know, Dr Longerich, that you can use "ausrotten" to 3mean "rooting out". It depends on the context? 4A.
[Dr Heinz Peter Longerich]
I am not sure about "rooting out". I think the meaning 5here of "ausrotten" is to wipe out, to get completely rid 6of. 7Q.
[Mr Justice Gray]
All right, wipe out? 8A.
[Dr Heinz Peter Longerich]
This applies not to -- I do not know, I mean, I am not 9familiar with the -- I mean, if you give me the time 10I will try to do my best to get familiar with the history 11of the churches, of a church in Salzburg in the 19th 12century, I am not sure whether they kill anybody or so. 13MR JUSTICE GRAY: Let us forget about ---- 14A.
[Dr Heinz Peter Longerich]
I think the term "ausrotten" applies to an organization 15which probably Protestentismus is here. It does not 16necessarily mean that everybody who belongs to this 17organization is going to be killed. You can also speak, 18I mean, today about "ausrotten" of criminality, for 19instance, if you mean, you know, that you get rid of this 20problem. But I think what is more important is that, you 21know, it is more tricky when it comes actually to the 22ausrotten of human beings, then I think the meaning is 23quite clear, as far I see it. 24MR IRVING: Can we now go to page 2 which is a 1935 Nazi 25reference to it, one which you have not adduced in your 26glossary. This is a speech by Rudolf Hess on May 14th. My

. P-30

1Lord, the translation is the final paragraph on that page. 2"National socialist legislation", the actual phrase which 3I am going to look at is "National Sozialische Deutschland 4des Judentums etwa richtiglos ausgerottet wurde". 5A.
[Dr Heinz Peter Longerich]
Where is that? 6Q.
[Mr Irving]
So there is a specific reference here to ---- 7MR JUSTICE GRAY: Fourth line? 8A.
[Dr Heinz Peter Longerich]
Yes. 9MR IRVING: --- the fourth line of the German. Here you 10have: "National Socialist legislation has now introduced 11corrective measures against this overalienisation. I say 12'corrective' because the proof that the Jews are not 13being ruthlessly ausgerottet", which I say is rooted out, 14"in National Socialist Germany, is that in Prussian alone 1533,500 Jews were working in the manufacturing industry, 1689,800 are engaged...", and so on. So he is talking 17clearly there about rooting out, is he not, not about 18liquidating because this is 1935, no one is killing Jews 19at that time, are they? 20A.
[Dr Heinz Peter Longerich]
I take your word that this is the authentical texts. 21I have not seen this document myself. I do not know the 22context. He is saying that the Judentum, which is 23probably the Jewry in this context, is not ausgerottet in 241935, which is perfectly true, I think. It is a 25preHolocaust document, I cannot see ---- 26Q.
[Mr Irving]
It is a Nuremberg document, is it not, if you look ----

. P-31

1MR JUSTICE GRAY: But the point that is being put, 2Dr Longerich, is that "ausrotten" is being used there in a 3context which has nothing to do with extermination. That 4is the only point that is being put. 5MR IRVING: By a Nazi, in connection with the Jews? 6A.
[Dr Heinz Peter Longerich]
Yes, so it is not the Jews, it is the Judentum, the term 7"Judentum" means here, let us say ---- 8MR IRVING: The Jewish community? 9A.
[Dr Heinz Peter Longerich]
--- the Jewish community, the alleged social position of 10the Jews in Germany, their property, their wealth and so 11on. So I think that, and so far the term means not only 12human beings, a collective, but it also means more than 13that, and in this sense the Judentum was not ausgerottet, 14so that is.... 15Q.
[Mr Irving]
The next page, Dr Longerich, on page 3 is the English 16translation, but you can look at the German, if you wish, 17which is on page 5. This is on item that you yourself 18have adduced. This is Adolf Hitler's use of the word 19"ausrottung" in 1936. He is not talking about Jews, but 20it is the same word. He is talking about the need for an 21economic four-year plan. On page 3 he puts in this 22sentence: "A victory of Bolshevism over Germany would not 23lead to a Versaille Treaty, but to a final destruction, 24indeed the ausrottung of the German nation", "volk". Is 25Hitler saying that if the Bolsheviks succeed in war 26against Germany, they are going to exterminate the German

. P-32

1nation? 2A.
[Dr Heinz Peter Longerich]
I am sorry. Normally, I have more time to interpret 3documents than this one or two minutes. 4Q.
[Mr Irving]
This is one referred that you yourself have referred to 5though, is it not, in your glossary? 6A.
[Dr Heinz Peter Longerich]
So I just have to look at it because I quoted it myself in 7my own document, he goes then on and says after you stop 8here, "And if the ausrottung", he tries to explain what 9"ausrotten" means. In English, it says here that: 10"After a Bolshevik victory, the European states, 11including Germany, would experience the most terrible 12catastrophe for its people since humanity was affected by 13the extinguishing of the states of classical antiquity". 14So I think if you say, "Well, this will be worse than the 15end of the Roman Empire", this statement involves clearly 16that this will be done in a very, that this ausrottung 17will be done in very cruel manner, it will cost a lot of 18lives. I think this is implicit here in Hitler's words. 19Q.
[Mr Irving]
But "ausrottung" here cannot be equated to the word 20"extermination", can it? He is not saying, "If the 21Bolsheviks win in a future war, it will lead to the 22extermination of the German people", he is saying, "It 23will lead to the emasculation of the German people or the 24end of them as an important power in Europe"? 25A.
[Dr Heinz Peter Longerich]
I would not agree because when he makes this reference, 26"It is more terrible than the end of the Roman Empire,

. P-33

1the states", he says. 2Q.
[Mr Irving]
Yes. 3A.
[Dr Heinz Peter Longerich]
Then it is quite something. I mean, this is not just, you 4the Versaille Treaty, as he said. It is not just the 5collapse of the German Empire; it is much, much more. 6Q.
[Mr Irving]
Hunger, starvation and pestilence. 7A.
[Dr Heinz Peter Longerich]
In a way, I am trying not to speculate what Hitler thought 8in 1936 what is actually more terrible than the end of the 9Roman Empire. I think it is quite reasonable to assume 10that this kind of "ausrottung" would, as the end of the 11Roman Empire did, involve the killing of many, many 12people. 13MR JUSTICE GRAY: Can you just for my benefit translate 14quickly, if you would not mind, the immediately following 15words, where he talks about what a catastrophe that would 16be? 17MR IRVING: "The extent of such a catastrophe cannot be really 18imagined". 19MR JUSTICE GRAY: Next sentence? 20MR IRVING: "How the densely populated west of Europe, 21including German, would survive after a Bolshevik 22collapse, it would experience probably the most awful 23national catastrophe since the extinction of the antique 24states -- since the" -- it is a complicated sentence. 25MR JUSTICE GRAY: It is a complicated sentence, but, 26Dr Longerich, it is all pretty apocalyptic stuff, is it

. P-34

1not, that he is ---- 2A.
[Dr Heinz Peter Longerich]
Yes. Exactly, and I think I translate it a little bit 3more, I said, "The most terrible catastrophe", 4"grauenhaft", I think is the word "terror" in it, and so 5it is ---- 6MR IRVING: "Awesome"? 7A.
[Dr Heinz Peter Longerich]
I think it is more than that. 8Q.
[Mr Irving]
Can I just ask you briefly about this document. This is, 9of course, a document dictated by Adolf Hitler to his 10private secretary, is it not? It is not a speech. He is 11choosing his words carefully. 12A.
[Dr Heinz Peter Longerich]
Yes. I do not know whether he dictated this to his 13private secretary. It is a document he provided for 14Goring. It is an instruction for Goring to carry on 15with ---- 16Q.
[Mr Irving]
Well, I know because Christa Schroeder told me he dictated 17it to her. 18A.
[Dr Heinz Peter Longerich]
I am trying to explain this to the court. It is the 19document which actually says that Germany should be able 20within four years to fight the next war. So it is an 21instruction for Goring. But I think if we go -- no, 22I cannot read more than that in this document. 23MR JUSTICE GRAY: We have your answer about that document 24anyway. 25MR IRVING: Yes. Page 6, again we are still in 1936, but 26collection of documents published obviously by anti-Nazis

. P-35

1now about the expropriation, the humiliation and the 2vernichtung of the Jews in Germany ---- 3A.
[Dr Heinz Peter Longerich]
Yes. 4Q.
[Mr Irving]
--- since the government of Adolf Hitler. This time it is 5the word "vernichtung". 6A.
[Dr Heinz Peter Longerich]
Yes. 7Q.
[Mr Irving]
1936, of course, the Jews as such had not been vernichtet, 8had they, and yet this is a history of the destruction of 9the Jews? 10A.
[Dr Heinz Peter Longerich]
I have to make here a general observation. I just have to 11trust that this is all, you know, this is original. 12Q.
[Mr Irving]
I have the original documents here. 13A.
[Dr Heinz Peter Longerich]
And I always prefer to look at documents in the 14appropriate context, but, of course, it is possible that 15somebody in '36, and I think these are the Jews who 16emigrated from Germany, would use the term "vernichtung" 17in a sense that, you know, "vernichtung" there, you would 18use it in the sense that he would not refer to the actual 19killing of the Jews because the actual killing, as we 20know, did happen later on. So I do not think how this 21document can help us to interpret or to put the Nazi 22terminology into the historical context. 23Q.
[Mr Irving]
Yes, I agree. It is a low grade document. It is outside 24Germany but there is the phrase "vernichtung der Juden" in 251936. 26A.
[Dr Heinz Peter Longerich]
Yes, and who actually published it, do you know that?

. P-36

1MR JUSTICE GRAY: Let us move on. It is a low grade document. 2MR IRVING: The next one is high grade. It is page 7, Walter 3Hewel? 4A.
[Dr Heinz Peter Longerich]
Yes. 5Q.
[Mr Irving]
Walter Hewel was a diplomat on Hitler's staff. He was the 6liaison officer, von Ribbentrop, was he not? 7A.
[Dr Heinz Peter Longerich]
Yes. 8Q.
[Mr Irving]
H-E-W-E-L? 9A.
[Dr Heinz Peter Longerich]
Yes. 10Q.
[Mr Irving]
And he wrote a memorandum on the conference between Hitler 11and this Czech State president Hacha -- H-A-C-H-A -- on 12March 15th 1939, which is in the official published 13volumes, is it not, ADAP? 14A.
[Dr Heinz Peter Longerich]
Well, again I cannot recall the document. I just trust 15that this is correct what you are saying. I do not have 16the ADAP with me and I do not have ---- 17Q.
[Mr Irving]
Well, if this is a fig quotation, no doubt, I will be shot 18down in due course by the Defence. The phrase in German 19is [German - document not provided] which I will translate 20as "If in the a autumn of the last year, 1938, 21Czechoslovakia had not given in, then the Czech volk would 22have been ausgerottet? 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
What is Hitler saying there? 25A.
[Dr Heinz Peter Longerich]
Well... 26Q.
[Mr Irving]
Is it important, do you think, this use of the word here?

. P-37

1MR RAMPTON: Do let him answer. One question at a time. 2A.
[Dr Heinz Peter Longerich]
I do not know about Hitler's plan, you know, it is a 3hypothetical question. It is assuming that the Munich 4agreement would not have happened, and so I do not know 5what was going on in Hitler's mind about the future of the 6Czechoslovak people, you know, in the case that would have 7been in 1938. So I cannot answer this question outside 8this. 9Q.
[Mr Irving]
Is Hitler telling the Czech State President, "Good thing 10you signed on the dotted line at midnight or 2 a.m. 11otherwise I would have liquidated your entire people", is 12that what he was saying? 13A.
[Dr Heinz Peter Longerich]
Forgive me, I do not know to which text you are referring 14now. 15Q.
[Mr Irving]
That is the context there. If the word "ausgerottet" used 16in Hitler's mouth talking about ---- 17A.
[Dr Heinz Peter Longerich]
Well, we have another document from the conversation 18between Hacha and Hitler where actually Hacha himself 19says, "Well, actually our people felt that -- our people 20are quite relieved because they feel now because they were 21on the assumption that they were going to be vernichtet in 22the case that, you know, the Munich agreement would not 23have kept ---- 24Q.
[Mr Irving]
How many Czechs were there? About 10, 15, 20 million? 25A.
[Dr Heinz Peter Longerich]
Are we talking about the Czech Republic? 26Q.
[Mr Irving]
Yes.

. P-38

1A.
[Dr Heinz Peter Longerich]
I think 7, 8 million or something like that, yes. 2Q.
[Mr Irving]
So Hitler is at this time, is this what you are saying, 3"I would have exterminated 7 million Czechs if you had 4not signed"? 5A.
[Dr Heinz Peter Longerich]
First of all, I do not know whether actually, but this is 6verbatim document, whether it implies some kind comment on 7Hitler, and then I am not sure -- it is a hypothetical 8question because what happened is that Czechoslovakia and 9the Western powers gave in and the Czechoslovak people 10were actually saved from a major catastrophe, may I say it 11like this, and I do not know what was going on in Hitler's 12mind in '38 about the future of the Czech people in case 13that, you know, he had not signed the Munich agreement. 14Q.
[Mr Irving]
Yes, but ---- 15A.
[Dr Heinz Peter Longerich]
But ---- 16Q.
[Mr Irving]
--- you do get the drift of my question, that here is that 17word "ausgerottet" in connection with a volk and Hitler 18saying, "I would have done it to them if you had not 19signed"? 20A.
[Dr Heinz Peter Longerich]
You know, it is a hypothetical. It is also, you know, 21Hitler sometimes uses, you know, he made threats and he 22threatened people and he made completely, you know, 23remarks which shows that he was out of control. So, you 24know, I do not know the context whether this is a kind of 25emotional reaction or anything like this. 26MR JUSTICE GRAY: What you are saying, it all depends on the

. P-39

1context? 2A.
[Dr Heinz Peter Longerich]
That is absolutely true. 3Q.
[Mr Justice Gray]
And is it also right that sometimes politicians, or Hitler 4anyway, would use a term like "ausrottung" meaning "wipe 5out"? 6A.
[Dr Heinz Peter Longerich]
Yes. 7Q.
[Mr Justice Gray]
Which is not to be taken literally? 8A.
[Dr Heinz Peter Longerich]
Yes, that is what I would say. 9Q.
[Mr Justice Gray]
That is why I am not really ---- 10MR IRVING: That is precisely the point I was going to ask. 11MR JUSTICE GRAY: It is all context, Mr Irving, is it not, 12really? 13MR IRVING: The final question on that quotation, therefore, 14is, is it not likely that Adolf Hitler was just saying, 15"If you had not signed, I would have ended Czechoslovakia 16as a power"? 17A.
[Dr Heinz Peter Longerich]
I think that is much, much stronger than that, 18"ausrottung", and again from the conversation with Hacha 19I know that Hacha was under the impression that the 20Czechoslovakian people would be vernichtet. 21Q.
[Mr Irving]
What did he mean by "vernichtet"? I know you used this in 22your glossary. 23A.
[Dr Heinz Peter Longerich]
I think that people had ---- 24Q.
[Mr Irving]
Gas chambers for the entire Czechs? 25A.
[Dr Heinz Peter Longerich]
No, but I think that people had felt, that people in 26Czechoslovakia in '38, felt that probably their existence,

. P-40

1probably their life was under danger. I think that is 2quite fair to say. 3Q.
[Mr Irving]
The entire Czech nation or just a few left wingers 4and ---- 5A.
[Dr Heinz Peter Longerich]
That people felt that their life was in danger. 6Q.
[Mr Irving]
Move on to the next passage, please? This is one you have 7quoted, is it not? This we do not have to argue whether 8he has been correctly reported or not because this is from 9a transcript of a speech that Hitler made to the Nazi 10editors on November 10th 1938. 11A.
[Dr Heinz Peter Longerich]
Yes. This is actually the day, the day after 12Kristallnacht, so the day, during the night approximately 13I think 90 or more people were killed, so this gives you a 14kind of background. Now, the term here Hitler is 15hesitating in this speech. He says, "Well" -- may be 16I should go, I have to go to my ---- 17MR JUSTICE GRAY: It is quite a complicated sentence. Can you 18translate it? 19A.
[Dr Heinz Peter Longerich]
Sorry, I have to go to my own text and I have to compare 20the two text. I am sorry about this. 21MR IRVING: While you are doing that, can I set it in context? 22Is Hitler saying ---- 23A.
[Dr Heinz Peter Longerich]
I am sorry, I cannot do this and listening to you. I have 24to find my ---- 25MR JUSTICE GRAY: Just pause a moment, Mr Irving. 26A.
[Dr Heinz Peter Longerich]
I have to find my own text. I know that it is somewhere.

. P-41

1MR RAMPTON: On page 21, in paragraph 6.12. 2MR JUSTICE GRAY: Yes, thank you very much, Mr Rampton. 3A.
[Dr Heinz Peter Longerich]
Yes. Yes, and then the sentence -- you did not give the, 4you stop in the middle of the sentence and you did not 5include the last five words, and the last five words in 6German are "aber man brauch Sie leider", "but we need 7them, unfortunately". So the context is that he is going 8to say, "Well, actually, you know, I could when I look at 9the intellectual classes in Germany, you know, one could, 10I could come to the conclusion", and then he is hesitating 11and saying "ausrottung", and then he goes on and says, 12"Well, unfortunately, we need them". So he is saying 13this idea to ausrottung, to kill the intellectual classes 14is completely illusionary, and so he has to come back and 15says, "I cannot do it". 16 You see, I have difficulties with this kind of, 17you know ---- 18MR IRVING: My Lord, can I just translate the sentence for you? 19MR JUSTICE GRAY: No, do not interrupt. 20A.
[Dr Heinz Peter Longerich]
--- I have difficulties actually to with these kind of 21documents which come in the last minute and leave out an 22important passage of the sentence, of the German 23sentence. Please give me sometime always to find the 24original if I have not got it in my report, I actually 25would like to insist that the original is here because 26I think this is not the way one can do it.

. P-42

1MR JUSTICE GRAY: Dr Longerich, I have some sympathy with that, 2particularly as you have pointed out that there is quite 3an important bit of that same sentence omitted in 4Mr Irving's piece of paper. 5MR IRVING: Can I just read out the translation of that 6sentence to you, my Lord? 7MR JUSTICE GRAY: No, because it has just been read out. 8MR IRVING: I do not think he has actually read out the 9translation. 10MR JUSTICE GRAY: Well, I have read it; I thought he did. 11THE WITNESS: I can do it if you want to. 12MR JUSTICE GRAY: Do if you want to, but include the last words 13because they make quite a big difference, it seems to me. 14MR IRVING: Not in my submission, but there we are. "I look at 15the intellectual classes amongst us, then, unfortunately, 16well, you need them, otherwise, I do not know, you could 17ausrotten them or something like that, but unfortunately 18you need them". I do not understand why you say I left 19out the words "man brauch Sie an"? 20A.
[Dr Heinz Peter Longerich]
Because you stop the sentence here with the colon and, in 21fact, the sentence is not stopping. You give as reference 22[German - document not provided] and this is not a 23complete, a complete sentence. You stopped in the middle 24of the sentence and left out the last five words. You 25should have used -- I mean ---- 26MR IRVING: Which are the words that I left out?

. P-43

1A.
[Dr Heinz Peter Longerich]
If your interpretation differs, you should have used, you 2know, the normal, you know, these little dots one uses if 3one does not insert the complete sentence. 4Q.
[Mr Irving]
Dr Longerich, which are the words you say that I left out? 5MR JUSTICE GRAY: He has said many times, "aber man brauch Sie 6leider"? 7A.
[Dr Heinz Peter Longerich]
"So you cannot kill them because we need them". 8MR IRVING: Are those words not on the fourth line of my 9quotation on page 7? "Man brauch Sie"? 10MR JUSTICE GRAY: Mr Irving, they are, but they come in twice 11and don't let us spend too long on this. 12MR IRVING: Precisely, my Lord, but the whole point I am 13looking at there is this is Adolf Hitler in 1938 when 14nobody is liquidating anybody ---- 15A.
[Dr Heinz Peter Longerich]
Except the 90 people who just died the night before, and 16this is the little exception one has. I mean, you have to 17realize the context is that this is the most brutal 18killing which happened in Germany since, I think, the 19Middle Ages. There are more than 90 people, I would say 20several hundred people possibly were killed the last 21night, and in this atmosphere Hitler is giving a press 22conference and speaks about the ausrottung of 23intellectuals. I think one cannot, you know, one has to 24look again at the historical context because this is, you 25know, an atmosphere which is dominated by brutality and a 26kind of absence of public order and law. I think, you

. P-44

1know, this has to be included here. 2Q.
[Mr Irving]
Your answer invites two questions, unfortunately. The 3first question is was Adolf Hitler, to your knowledge, at 4the time you made this speech on the afternoon of November 510th aware that 90 people had been killed during the 6night? 7A.
[Dr Heinz Peter Longerich]
I do not know. I do not know that. 8Q.
[Mr Irving]
The second question is, are you, therefore, suggesting 9that the verb "ausrotten" is not a mass extermination but 10a midget extermination, if I can put it like that, of just 1190 people? Is that the scale you put "ausrotten"? 12I thought that "ausrotten" meant extermination on a huge 13scale. 14A.
[Dr Heinz Peter Longerich]
No, I am just saying that when he made this, he made the 15statement and the statement says, "I can't kill them, I 16would like to but I can't kill them", but one has to look 17at the atmosphere of this very day. 18MR JUSTICE GRAY: It always comes back to context? 19A.
[Dr Heinz Peter Longerich]
That is what I am trying to say. 20MR IRVING: Precisely, but a perfectly reasonable 21interpretation of the word "ausrotten" there would be get 22rid of them, abolish the intellectual classes, abolish 23the ---- 24A.
[Dr Heinz Peter Longerich]
The translation here ---- 25Q.
[Mr Irving]
--- upper classes? 26A.
[Dr Heinz Peter Longerich]
Sorry. I think the translation, the proper translation,

. P-45

1is to kill them all, but, unfortunately, I cannot do it. 2I have said this now three times and I think it is-- I do 3not want to ---- 4Q.
[Mr Irving]
Adolf Hitler was telling the editors of the leading 5newspapers in Germany, "I just wish I could kill all the 6intellectuals" in 1938? 7A.
[Dr Heinz Peter Longerich]
Yes, "But I cannot do it, unfortunately". That is what it 8says in the text here. 9Q.
[Mr Irving]
Yes. This is the image you now have of that kind of thing 1055 years later, but how would the editors have picked up 11at the time if that was the meaning of the word 12"ausrotten" in 1938? You appreciate that the meaning of 13words change over the years and when Adolf Hitler uses the 14word in 1938, the editors sit there thinking, "Yes, he 15wants to abolish them, he wants to get rid of the upper 16classes", just the same as Tony Blair gets rid of the 17House of Lords? 18MR JUSTICE GRAY: No, not the upper classes. I do not think 19that is right. 20A.
[Dr Heinz Peter Longerich]
The intellectual classes -- well, then he could have said, 21"Well, actually I want" -- I said this here in my report, 22I said if he were just referring to a kind of, you know, 23social, you know, reform or reform of the educational 24system or some leveling of class, something like that, he 25could have said so. He could have said, "Actually I want, 26you know, to be more, Hitler jungen in the universities.

. P-46

1I do not want to get -- I would like to get rid of the 2sons of academics, well-established people", but he says 3he used the term "ausrotten". I cannot help this-- it is 4here and ---- 5Q.
[Mr Irving]
Just one more question on that. Would it not be a 6parallel if Tony Blair said he wanted to rid of the House 7of Lords, wipe out the House of Lords, would he not say 8"ausrotten" there and would that mean that he wanted to 9stand them against a wall? 10A.
[Dr Heinz Peter Longerich]
That is a hypothetical question. How can I answer this 11question? 12Q.
[Mr Irving]
But it is that kind of word and that kind of situation, is 13it not? "This is a body which is bothering me. I wish 14I could, "Out, out, damn spot"? 15A.
[Dr Heinz Peter Longerich]
If you ask me as an historian, I should make a historical 16comparison, then you have to include in this picture that 17Tony Blair just killed 91 Conservative Member of 18Parliament. So this would give you a kind of -- and then 19if he would use at the same time, at the next day the term 20"ausrotten", I would look at it and say, "Well, a 21dangerous man". 22MR JUSTICE GRAY: Mr Irving, let us move on because really this 23is not, I think, a very helpful exercise. 24A.
[Dr Heinz Peter Longerich]
It is difficult for me to make such comparisons. 25MR IRVING: I did not drag in the 90 deaths and I am going to 26have to ask a question. Did Hitler order the Jews killed

. P-47

1that night? 2A.
[Dr Heinz Peter Longerich]
Did Hitler? 3Q.
[Mr Irving]
Or did Hitler order the Jews killed in 4Reichskristallnacht? 5MR JUSTICE GRAY: I do not think that bears on the issue we are 6considering at the moment. 7MR IRVING: It bears on the questions of intent behind the word 8"ausrottung"? 9A.
[Dr Heinz Peter Longerich]
Well, I think that Hitler played a centre role in the 10launching of the Kristallnacht. 11Q.
[Mr Irving]
We know your views on that. 12A.
[Dr Heinz Peter Longerich]
Pardon? 13Q.
[Mr Irving]
Can you now go to document No. 8, please? 14MR JUSTICE GRAY: You did ask the question, Mr Irving. 15MR IRVING: He then answered a totally different question 16whether Hitler played a central role or not. 17MR JUSTICE GRAY: Let us move on if we have to do this 18exercise, let us do it quite quickly. 19MR IRVING: Page 8. 20A.
[Dr Heinz Peter Longerich]
I could not complete my answer, sorry. 21Q.
[Mr Irving]
This is a 1941 document, a book again in German [German - 22document not provided] 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
Was Hungary exterminating the ethnic minorities? 25A.
[Dr Heinz Peter Longerich]
Well, you see, give me the chance, you know, to read the 26book. Maybe the book, it might be a pamphlet from

. P-48

1somebody who said, well, actually the Hungarians are 2killing, literally killing, the minorities. I do not know 3the order. I do not know whether Paclisanu is a reliable 4author. I have not seen the book and I do not know 5whether the book says -- I do not know whether you have 6read the book -- if the book says that the Hungarians are 7killing the minorities. There might be somebody ---- 8MR JUSTICE GRAY: I think that is a fair answer. Without that 9further information, I do not think that particular cover 10page really helps. 11MR IRVING: Well, if this expert witness can answer the 12question whether Hungary was killing ethnic minorities, 13that would clarify what the title meant. 14A.
[Dr Heinz Peter Longerich]
No, I do not -- that is in 41. I am a bit hesitating here 15because, well, they actually were quite rude with 16the minorities after that, but I cannot comment on that 17without actually looking at the content of the book. 18Q.
[Mr Irving]
Dr Longerich, at this stage in our discussion, therefore, 19we can agree that the word "ausrotten" can mean just about 20whatever you want it to mean? 21A.
[Dr Heinz Peter Longerich]
No, clearly not. You have to look at the context and the 22context will help you to establish a meaning of the word, 23I think. 24Q.
[Mr Irving]
If you turn the page now to page 9, this is my summary of 25a telegram which I found in the Roosevelt library. 26A.
[Dr Heinz Peter Longerich]
Yes, I would suggest that I should comment not on your

. P-49

1summary but on the original, given the experience we have 2before. 3Q.
[Mr Irving]
That is one way out of answering the question, is it not? 4MR JUSTICE GRAY: No, Mr Irving, that is not fair. Do you 5refer to this yourself, Dr Longerich? 6MR IRVING: No, he does not. 7A.
[Dr Heinz Peter Longerich]
No. Sorry for interrupting you. 8MR IRVING: Are you suggesting, therefore, that I have 9deliberately copied faked quotations from a telegram from 10my own files? 11A.
[Dr Heinz Peter Longerich]
No, but I have the experience and that quite upset me that 12you left out here half a sentence of a sentence without 13actually ---- 14Q.
[Mr Irving]
Which repeated the precisely the same four words that were 15earlier in the sentence, right? 16MR JUSTICE GRAY: We have left that document. Let us look at 17this one. 18A.
[Dr Heinz Peter Longerich]
I am just saying, I am not just -- I am not happy, you 19know, just to comment on your summary of a report I have 20not seen in the original. I think it would be 21inappropriate for me, as an historian, to comment on 22that. I should see the original and I should not draw 23conclusions from your summary. 24MR IRVING: Shall we try, unless his Lordship says that 25I should not ask the question about this? 26MR JUSTICE GRAY: This appears to be -- is it Swiss?

. P-50

1MR IRVING: It is an American diplomatic despatch in the 2Roosevelt Library. 3MR JUSTICE GRAY: Commenting on whether a word in a report 4which we do not have has been correctly translated. 5MR IRVING: It appears that this report may be based on 6mistranslation of the words ausrottung and entjudung. Is 7it possible therefore to mistranslate the words ausrottung 8and entjudung? 9A.
[Dr Heinz Peter Longerich]
I have to fully digest, just one second. 10Q.
[Mr Irving]
It is a bit of problem if you always have to produce the 11whole document or the original report, you do appreciate 12that. 13A.
[Dr Heinz Peter Longerich]
So your question is what, sorry? 14Q.
[Mr Irving]
The question, if you are prepared to answer a question on 15this summary, or extracts from an American diplomatic 16despatch, is it possible to mistranslate the word 17ausrottung and entjudung in a way which might go one way 18or might go the other. Even in 1944, in other words, 19there is no firm and fixed definition or translation? 20A.
[Dr Heinz Peter Longerich]
Well, somebody speculates about the issue whether the 21words ausrottung and entjudung were mistranslated. 22Q.
[Mr Irving]
Yes. 23A.
[Dr Heinz Peter Longerich]
And how shall I comment on that? 24MR JUSTICE GRAY: I find this frankly an absurd document 25because the report appears to refer to the extermination 26of European Jews at camps in Silesia?

. P-51

1A.
[Dr Heinz Peter Longerich]
Yes. 2Q.
[Mr Justice Gray]
It refers to a cyanide process and to German executions 3and then Mr Harrison, whoever he may be, thinks that 4ausrottung has been mistranslated. It is an absolute 5nonsense. 6MR IRVING: I am only relying on the mistranslation, the fact 7that it is possible to mistranslate the word ausrottung. 8That is all I can do with that particular document. 9A.
[Dr Heinz Peter Longerich]
If you want me to comment on it, I should be able to know 10more about the facts than Mr Harrison did, shall I put it 11this way? At the moment I do not know what I should do 12with this document. 13Q.
[Mr Irving]
The final sentence, of course, "I spoke yesterday with one 14of the men who planted the report with the newspaper 15agencies". Did this kind of thing go on during the war 16years, that documents were planted with newspaper 17agencies? 18A.
[Dr Heinz Peter Longerich]
During the war documents were planted with newspaper 19agencies, yes. That happened. 20Q.
[Mr Irving]
You always want to see original documents. If you turn 21the page to the next one which is unnumbered, is this the 22kind of document you are familiar with from Himmler's 23files? You may actually know it, in fact, because it is 24addressed to your subject Martin Bormann, is it not? 25A.
[Dr Heinz Peter Longerich]
Yes. I became quite familiar with him, that is true. 26Q.
[Mr Irving]
It is dated 21st February or thereabouts, 1944?

. P-52

1A.
[Dr Heinz Peter Longerich]
Yes. It says that the misstande, what is misstande in 2English? 3Q.
[Mr Irving]
Bad conditions? 4A.
[Dr Heinz Peter Longerich]
Yes something like that. 5Q.
[Mr Irving]
Naff, as they say in America. 6A.
[Dr Heinz Peter Longerich]
Can I ask the interpreter something? 7MR JUSTICE GRAY: Yes, of course. 8THE INTERPRETER: Things which are not right, things which need 9putting right. 10A.
[Dr Heinz Peter Longerich]
So he is not referring to people. He is referring to 11things which are not going right. He is saying that these 12misstande, these things which are not right, will be 13ausgerotet, so of course the term ausgerotet, you could 14give me thousands of documents which would show me that 15misstande ausgerotet were meant, ausgerotet, everything, 16every possible context. 17MR IRVING: It has been dictated by Himmler, has it not? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
Himmler's use of the word ausrottung in a non homicidal 20sense, that is all I am relying on this document for. 21A.
[Dr Heinz Peter Longerich]
You can prove from this document so far that Himmler used 22the term ausrottung once, not referring to human beings 23but to misstande in a non-homicidal sense, yes, that is 24true. 25Q.
[Mr Irving]
Dr Longerich, all I am trying to establish here in the 26beginning of the 21st century is that back in the 1940s

. P-53

1the word ausrottung did not have necessarily the meaning 2that we now give it, with our knowledge of all the 3atrocities that happened. Do you accept that? 4A.
[Dr Heinz Peter Longerich]
I myself in my report made a little reservation here and 5I said, well, not every time the word ausrotten means 6killing, but if it refers to people, or to a group of 7people, in the historical context of the Nazi period, 8I did not find a single document in which one would not 9translate the word ausrotten to kill in large numbers or 10to kill all as far as possible. This is my provisional 11conclusion. 12Q.
[Mr Irving]
Wipe out? 13A.
[Dr Heinz Peter Longerich]
I think wipe out is a possible translation. Exterminate 14is another one. Kill off, or extirpate, which is the one 15I preferred. But I think for the German living at this 16time the term from a leading Nazi or national socialist, 17the term ausrotten applying to people means quite clearly, 18I mean for the average German at this time means quite 19clearly to kill in large numbers. It is a very cruel 20expression and of course there is a lot of violence in 21this word. 22Q.
[Mr Irving]
Yes. Can you not put yourself back in the mind set of the 231940 when the word possibly had a different meaning? 24A.
[Dr Heinz Peter Longerich]
I think particularly at this time, because at this time 25people lived in the time when people were killed on a 26massive basis, they were quite aware that the use of this

. P-54

1vocabulary by leading Nazis referred to mass killing. Why 2should I speculate in a general way? One could look at 3the individual documents and establish the meaning. It 4does not help us, I think, to look at documents which are 5outside the context. 6MR IRVING: You have to have some kind of guiding star to look 7at, do we not? 8A.
[Dr Heinz Peter Longerich]
That is fine. 9Q.
[Mr Irving]
Go to the next page, page 11, which is a 1944 military 10dictionary. We are getting pretty close to the actual 11meaning of 1944 if we accept that the dictionary was 12probably printed a year or two earlier. No, it was 13actually printed in 1944. That is what page 10 shows us. 14MR JUSTICE GRAY: Military dictionary? 15MR IRVING: Military dictionary, yes. 16A.
[Dr Heinz Peter Longerich]
Yes. 17Q.
[Mr Irving]
Which is a dictionary produced just for the use of the 18armies. It contains all sorts of things, too. There you 19have the meaning of the word ausrotten given in the 20following sequence: Wipe out, crush, annihilate. Wipe 21out is probably right. 22A.
[Dr Heinz Peter Longerich]
I again am not a linguist but, if I look at the other 23terms on this page, it is obviously that this is a 24dictionary for military terminology, so it refers I think 25particularly to the military sphere. But again I am quite 26convinced that you can present more dictionaries which

. P-55

1actually do not have the meaning of extermination. 2I could probably show you dictionaries which have the 3meaning of ---- 4MR JUSTICE GRAY: I am really finding this all pretty 5unilluminating really, because in the end we have to look 6at the documents which actually do relate allegedly to 7extermination, and decide whether ausrotten in that 8context means extirpate. 9MR IRVING: My Lord, it is an uphill task because we are 10looking backwards, down through the telescope so to speak, 11to the events of the 1940s and trying to work out what a 12word meant when in common usage at the time, when we find 13the common meaning of the word was quite different from 14the way every German, and every Englishman, now 15understands what you mean by it, because we know of the 16atrocities that happened. 17MR JUSTICE GRAY: One has to make allowance for that fact, I 18accept. 19MR IRVING: The reason I am going through this, if I can put it 20like this, is that, if we are looking at what Adolf Hitler 21means when he says certain things or issued certain 22orders, we really need to know what the word meant in 23common usage at that time, and not what it now means at 24the beginning of the 21st century. 25MR JUSTICE GRAY: We really have spent a very long time on 26ausrotten and I think we have the full rage of

. P-56

1possibilities in mind. 2MR IRVING: That is the bad news. The good news is frankly 3that I am going to accept without demur that most of the 4meanings he applies to the other words, like Umsiedlung 5and the rest. 6A.
[Dr Heinz Peter Longerich]
I think I have to say here that I last night found three 7mistakes in the translation. I think I should correct 8them. 9MR JUSTICE GRAY: I think you probably should. 10A.
[Dr Heinz Peter Longerich]
I know that I am responsible in the end -- I am not 11blaming the translator, I am responsible and for the 12text. It is in point 5.9 and it is on page 14. I think 13the term Juda must die should be translated not with 14Judaism must die, but simply with Juda must die, because 15it refers I think basically to the tribe of Juda and 16I think one cannot and should not translate the tribe of 17Juda with Judaism which has another meaning. The same 18would apply to 6.14. There is the same mistranslation. 19I apologise for that. In 6.7 actually the word nicht is 20not translated, so in 6.7 it says in the indented 21paragraph in the second sentence what does die and it 22should say what does not die. So this is unfortunately a 23mistake. I am sorry about that. 24MR JUSTICE GRAY: Do not worry, that is fine. Shall we move 25elsewhere? 26MR IRVING: We are now dealing with your glossary. I must say

. P-57

1I take exception to the title of your glossary because 2this assumes a priori that there was such a programme to 3exterminate or murder. Really what we are looking at is a 4glossary of terms used by the Nazis in their programme of 5persecution of the Jews, is it not? It includes murder in 6some cases but it is all sorts of other things, is it not? 7A.
[Dr Heinz Peter Longerich]
In connection with a murder. 8Q.
[Mr Irving]
Yes. You say in your paragraph 1.1 of your introduction, 9that the Nazi regime avoided speaking of the murder of 10European Jews by name, in other words they did not like 11saying it. 12A.
[Dr Heinz Peter Longerich]
Yes. 13Q.
[Mr Irving]
Do you not yourself say in your report, I think it is 14round about paragraph 4.3.1 that the Einsatzgruppen 15reported quite frequently in most glowing terms of the 16killings they were carrying out and they made no bones 17about what they were doing? 18A.
[Dr Heinz Peter Longerich]
I said here generally, so the Einsatzgruppen, of course 19there are exceptions and the most known exceptions are the 20Einsatzgruppen reports. If you look into the history of 21the Holocaust, this is rather a rare example, I think. 22Historians of the events in Russia are quite happy to have 23this, if I may use this term here, this source, but 24generally you are looking at the whole system. They were 25quite reluctant to use openly this expression. 26MR JUSTICE GRAY: Yes.

. P-58

1MR IRVING: Except that it is rather odd that you should argue 2on the one hand there is this colossal use of euphemisms 3everywhere, but on the other hand everyone is talking 4about killing. 5A.
[Dr Heinz Peter Longerich]
No, not everybody is talking about killing. I made it 6quite specific. We have some exceptions and the 7Einsatzgruppen reports are the best example for that. Of 8course there are more exceptions, but generally, and this 9explains why we do not have more documents, we should 10imagine that an operation like this, the killing of about 116 million people, in the 20th century we should have more 12documents on that, because it was an operation on an 13unprecedented scale. But to explain that actually the 14number of documents is in a way limited, I am saying here 15generally they prefer not to speak about the killing. 16Q.
[Mr Irving]
Yes. 17A.
[Dr Heinz Peter Longerich]
So in newspapers, for instance, and things like that they 18did not announce on the first page that we are killing the 19Jews today, 5,000 people got killed in Auschwitz. They 20tried to keep it as a state secret. Even in the 21bureaucracy you find the kind of hesitation. It was 22actually forbidden to use this terminology within the 23bureaucracy. Of course there were exceptions. 24Q.
[Mr Irving]
You refer to the speech by Heinrich Himmler at Posnan on 25October 4th 1943 in your paragraph 1.2. 26MR JUSTICE GRAY: 43 or 44?

. P-59

1MR IRVING: It was actually 1943. I think that is mistake in 2the report, my Lord. 3A.
[Dr Heinz Peter Longerich]
1943, yes. That is a mistake. 4Q.
[Mr Irving]
That is quite an ordinary speech, is it not? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
Why is it extraordinary in the context of what we are 7talking about this morning? 8A.
[Dr Heinz Peter Longerich]
Yes, he is saying: I also want to talk to you quite 9frankly about a very grave matter, we can talk about it 10quite openly among ourselves, but nevertheless we can 11never speak of it publicly, just to underline my point, 12just as we did not hesitate on 13th June 1934 to do our 13duty as we were bidden and to stand comrades who had 14lapsed up against the wall and shoot them, so we have 15never spoken about it and will never speak of it. It was 16a natural assumption, an assumption which, thank God, is 17inherent in us, that we never discussed it among ourselves 18and never spoke of it. That is I think a remarkable 19passage. Then he is going on: "Most of you will know what 20it means to have 500 of a thousand corpses lying together 21before you. We have been through this and, disregarding 22exceptional cases of human weakness, to have remained 23decent. That is what has made has made us tough. This is 24a glorious page in our history, once that has never been 25written and can never be written". Of course, the last 26sentence is a kind of challenge for historians, I think.

. P-60

1Q.
[Mr Irving]
He is talking about the shootings on the Eastern Front, is 2he not? He is not talking about the western European 3Jews. He is talking about here about the killings, the 4machine gunnings into pits and so on? 5A.
[Dr Heinz Peter Longerich]
I am always quite cautious. He is talking about the 6killing of hundreds of people. I cannot see whether he 7refers to shootings, or whether he refers to extermination 8camps, or to labour camps, I have no idea. 9Q.
[Mr Irving]
As you say yourself, he says, "most of you will know what 10it means to have 500 or a thousand corpses lying together 11before you". He is referring to the shootings on the 12Eastern Front is he not? 13A.
[Dr Heinz Peter Longerich]
Not necessarily. He could also refer to extermination 14camps. 15MR JUSTICE GRAY: This is a speech to SS officers, is it not, 16not to the generals or anything of that kind? 17Q.
[Mr Irving]
To the SS Gruppenfuhrer. 18A.
[Dr Heinz Peter Longerich]
To the SS GruppenFuhrer, that is true. 19Q.
[Mr Irving]
He had this speech recorded on disk, did he not? 20A.
[Dr Heinz Peter Longerich]
That is true. 21Q.
[Mr Irving]
Did that indicate that he was particularly concerned about 22secrecy? 23A.
[Dr Heinz Peter Longerich]
I think the procedure was, it was not uncommon that he had 24his speeches on disk. He would give the disks to his 25personal adjutant and Brandt, and Brandt would then write 26a good manuscript, what actually improved the wording and

. P-61

1so on. So I think the disk was primarily meant to be used 2for internal purposes, just to record exactly the words of 3the speech and to take it as a basis for an extended and 4improved minute. I think it was not intended to broadcast 5the speech or something like that, definitely not. 6Q.
[Mr Irving]
We had a discussion here about the script of that speech, 7the transcript that was made. 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Irving]
Are you aware that he required those who had not read it, 10or had not attended it rather, to sign a list saying that 11they had in the meantime read the speech? 12A.
[Dr Heinz Peter Longerich]
It may be right. I cannot recall this, but I think you 13are right. 14Q.
[Mr Irving]
Yes. It is in my discovery. It is a two or three page 15list of the names of all the SS Gruppenfuhrer and they had 16been required to confirm either that they have heard this 17speech or that they have since read it? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
Would you like to speculate from your knowledge as an 20expert on this why Himmler would have wanted to make sure 21that they had all heard the politics of the Third Reich? 22A.
[Dr Heinz Peter Longerich]
One should not speculate, but it is a very long speech. 23I think it is probably more than 50 pages or something 24like that. 25Q.
[Mr Irving]
Yes. 26A.
[Dr Heinz Peter Longerich]
He refers to the killing of the Jews. It might be that he

. P-62

1wants them to share this secret with him, but it could 2also mean that he just thought it was an important speech 3and they should listen to him, and they should be aware, 4because he is speaking about the conduct of war and all 5other important issues. So I am not absolutely sure that 6this is particularly this issue, why he is doing that. 7Q.
[Mr Irving]
Let me put it like this. Are you aware of any other 8Himmler speeches where he required those who had not 9attended to read it like school children afterwards? 10A.
[Dr Heinz Peter Longerich]
I am not sure, I cannot say anything to that. 11Q.
[Mr Irving]
Can you take it from me that I have never seen any other 12such list from any other Himmler speech? 13A.
[Dr Heinz Peter Longerich]
No. I am afraid I have to say it might be, but I cannot 14recall that. 15Q.
[Mr Irving]
Are you prepared to suggest that there is a link between 16the fact that he made this extraordinary expose in this 17speech with the fact that he required all the SS generals 18to sign that they had now taken cognisance of it? 19A.
[Dr Heinz Peter Longerich]
If I should speculate on it in this sense, yes, it is 20possible. 21Q.
[Mr Irving]
Probably a link? 22A.
[Dr Heinz Peter Longerich]
Yes. 23MR JUSTICE GRAY: I am not quite sure, Mr Irving, what the 24suggestion you are making is. What are you saying that 25the reason was? 26MR IRVING: I was just about to try and elicit this. I think

. P-63

1undoubtedly that Dr Longerich is an expert on these 2matters and I would be interested to hear his views. 3MR JUSTICE GRAY: Yes. You are perfectly entitled to ask, but 4I was not quite sure what the suggestion was. 5MR IRVING: Is there some suggestion that Himmler is making 6them all into accomplices after the fact? 7A.
[Dr Heinz Peter Longerich]
That is a possible interpretation. 8Q.
[Mr Irving]
Of something that he has done. Is he trying to spread the 9guilt, do you think? 10A.
[Dr Heinz Peter Longerich]
It is a possible interpretation, yes. 11Q.
[Mr Irving]
Am I right, if I can ask a general question here, in 12saying that we are very much in the dark when we get up to 13this rarified level of Heinrich Himmler, Adolf Hitler, we 14do not really know what happened between them? We are 15forced to speculate, depending on our own personal 16positions. 17A.
[Dr Heinz Peter Longerich]
Yes, to speculate. We are in a way informed speculators 18so I think we have some sources and we should always take 19those sources as a basis for our speculation. And of 20course it is the nature of the system, the genre of 21decision making. We know there is a record of the 22relationship between Himmler and Hitler before this time, 23so we are also allowed, I think, to draw a conclusion from 24this wider context. 25MR JUSTICE GRAY: You have not told me what your conclusion is? 26A.
[Dr Heinz Peter Longerich]
My conclusion?

. P-64

1Q.
[Mr Irving]
The question really was, we do not know much about the 2relationship between Himmler and Hitler. 3A.
[Dr Heinz Peter Longerich]
We know something about the relationship between Himmler 4and Hitler. 5MR IRVING: Specifically in this connection, am I right, my 6Lord? 7MR JUSTICE GRAY: It was your question I was paraphrasing. 8MR IRVING: I am sure it would interest your Lordship too to 9know, from your own personal knowledge as an expert 10particularly on the Party Chancellery files, for example, 11is there any hint in all that huge body of, as you say, 1250,000 documents which suggests that there were intimate 13discussions between Himmler and Hitler on the Final 14Solution with a homicidal intent, if I can put it like 15that? 16A.
[Dr Heinz Peter Longerich]
Not necessarily in the files of the Party Chancellery but, 17if I can expand on that, the sources we have relating to 18Hitler and Himmler, I would say, the most important 19document we have, is the entry in the Dienskalendar, the 2018th December 1941. This is of course an important 21document. We have the speeches, not only this speech, but 22also a couple of other speeches, a couple of speeches 23Hitler made to this issue. We have a number of other 24documents which I refer to in my report number 1. 25Q.
[Mr Irving]
We will come to them. 26A.
[Dr Heinz Peter Longerich]
So we have documents from 42, where Himmler said, "the

. P-65

1occupied Eastern territories have to be made free of Jews, 2this is a burden on my shoulders, it was laid as a burden 3on my shoulders". We have more documents like this, which 4gave us a kind of insight into the relationship. They 5actually were discussing the issue of the Holocaust among 6them. 7MR IRVING: Is it not a danger you refer to the December 18th 81941 document. That of course only turned up two years 9ago. Does that mean to say that for 53 years people were 10really reaching these conclusion without such a document, 11finally like a drowning man they found a straw? 12A.
[Dr Heinz Peter Longerich]
No. The other documents are not known, and it added to 13our picture. As you suggested yourself, it is luck that 14we actually opened, that we have access now to Eastern 15European archives, but they were not in the dark before 16that. It adds to our knowledge. 17MR JUSTICE GRAY: Just so I am clear, you say that the informed 18speculator would draw the conclusion that Hitler and 19Himmler were discussing the Holocaust. By the Holocaust 20in that connection you do not just mean the shootings by 21the Einsatzgruppen? 22A.
[Dr Heinz Peter Longerich]
No, I mean the systematic killing of European Jews. 23Q.
[Mr Justice Gray]
By whatever means? 24A.
[Dr Heinz Peter Longerich]
By whatever means, yes. 25MR IRVING: What would you say to the historian who says that 26such speculation is without foundation if one looks at it

. P-66

1objectively? 2A.
[Dr Heinz Peter Longerich]
I would reject this view. 3Q.
[Mr Irving]
Yes. Would you say that one's personal political 4viewpoint come into it, that the extreme right-winger 5would adopt one view and the cautious German historian, 6aware of the laws in Germany, would adopt a different 7view? 8A.
[Dr Heinz Peter Longerich]
I do not know to which laws are you referring. I publish 9all my books in Germany. I never felt any restrictions on 10publishing books. 11Q.
[Mr Irving]
I am sure. 12A.
[Dr Heinz Peter Longerich]
As far as the own political viewpoint is concerned, the 13ideology, I think we have to rely on our professional 14work. So we have to just try to exclude this fact as far 15as it is possible. We have some rules how to interpret 16sources, how to deal with material, and I think what we do 17is, generally speaking, reliable. You can rely on that. 18Q.
[Mr Irving]
Would you classify the great body of German historians as 19being diligent and applying themselves to the task? 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Irving]
Why did they wait for 25 years before looking at Heinrich 22Himmler's handwritten notes of his telephone conversations 23with Hitler? 24A.
[Dr Heinz Peter Longerich]
Which ones are you referring to? 25Q.
[Mr Irving]
The notes in Himmler's handwriting which were in the 26National Archives in America and available on microfilm

. P-67

1since the 1950s and I was first person to use? 2A.
[Dr Heinz Peter Longerich]
If you give me a specific reference to one quote, and you 3can go through the works of my colleagues and find out 4whether they left something out, I think that -- well, 5stop here. 6Q.
[Mr Irving]
Yes. Let me put the question this way round. I do not 7want to go too far down this avenue, but are you aware of 8any other German historian who, before 1975, made any use 9of Heinrich Himmler's handwritten notes on his telephone 10conversations or meetings with Hitler? 11A.
[Dr Heinz Peter Longerich]
Before 1975? 12Q.
[Mr Irving]
Approximately, when my book Hitler's War was published. 13A.
[Dr Heinz Peter Longerich]
Actually, I cannot recall that. 14Q.
[Mr Irving]
Yes. 15A.
[Dr Heinz Peter Longerich]
I cannot actually answer this question because I cannot 16recall every word which was published before 1975. But, 17if you are making the point that you were one of the 18first, or probably the first, who was using the documents, 19I agree. 20Q.
[Mr Irving]
That is not the point I am trying to make. I am 21suggesting that, if an historian has not shown proper 22diligence in turning up and using the sources, then how he 23cares to speculate is not worth the paper he writes his 24speculations on. 25A.
[Dr Heinz Peter Longerich]
I am reluctant to make a general statement about the 26historians. If you talk about a certain person, a certain

. P-68

1author, you can discuss his books, whether the sources are 2available or not, but I am really hesitant to make a 3general sweeping statement about all my colleagues in 4Germany. 5MR JUSTICE GRAY: The answer you gave me just now about what 6the informed speculator would infer was based on all the 7now available evidence including the Himmler diaries? 8A.
[Dr Heinz Peter Longerich]
One would try to include these documents into one's own 9interpretation, yes. 10MR IRVING: It is right that we are learning the whole time, 11are we not, that more and more documents become available, 12particularly from the Moscow archives and from your own 13work, for example, on the Martin Bormann papers? We are 14constantly adding to our information, so we are correcting 15misinterpretations, we are correcting even mistranslations 16sometimes, or misreadings? 17A.
[Dr Heinz Peter Longerich]
Yes. It is a research process, that is true. 18Q.
[Mr Irving]
You rightly point out the fact that Muller in January 1942 19said the word liquidierung was not to be used? 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Irving]
Which is understandable. If you are familiar with my 22Goebbels biography, do you know that it was Dr Goebbels 23who first issued that order? 24A.
[Dr Heinz Peter Longerich]
No. 25Q.
[Mr Irving]
Sometime in November or December 1941, Goebbels issued a 26propaganda directive that the word liquidate is only going

. P-69

1to be used in connection with the Soviet killings? 2A.
[Dr Heinz Peter Longerich]
Interesting. I am not aware of that, no. 3Q.
[Mr Irving]
But liquidierung is quite plain. We do not have to argue 4about the meaning of that word of course. 5A.
[Dr Heinz Peter Longerich]
No, definitely not. 6Q.
[Mr Irving]
But on paragraph 2 we now come to Umsiedlung and the 7various other words with this settlement route. 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Irving]
It is correct to say that these words are used in both 10homicidal and non-homicidal senses throughout the 11documentation. Sometimes Umgesiedlung means they are 12going to be literally, as we saw in one document, in the 13same paragraph concerning Brestitovsk Jews in October 141942, we saw one document where at the beginning of the 15paragraph it referred to, I think, 15,000 Brestitovsk Jews 16had been Umgesiedelt, which is shot, and then at the end 17of the same paragraph it said, "The village of A, half the 18Jews had been shot and the rest had been Umgesiedelt to a 19neighbouring village", and that is a typical case of the 20problem facing us, is it not, with this particular word? 21A.
[Dr Heinz Peter Longerich]
I do not have this document in front of me but in general 22I could agree. 23MR JUSTICE GRAY: Assume it is true because we have been 24through it more than once. 25A.
[Dr Heinz Peter Longerich]
That makes it so important to look at the context. 26MR IRVING: Sometimes we just do not have the context to judge,

. P-70

1is that right? 2A.
[Dr Heinz Peter Longerich]
We try our best to establish the context. 3Q.
[Mr Irving]
Sometimes when the Jews were sent just to ghettoes, that 4is where the word "umgesiedelt" is used, is it not? 5A.
[Dr Heinz Peter Longerich]
Give me please some kind of reference and I will comment 6on it, because it is a very difficult subject because the 7meaning, as you rightly said, changes and can change in 8the same document. So I should refer, I should in my 9answer refer to single documents. 10Q.
[Mr Irving]
Yes, in paragraph 2.2, you refer to a Wehrmacht report. 11It is not even an SS report, is it? 12A.
[Dr Heinz Peter Longerich]
Yes. 13Q.
[Mr Irving]
So the German Army was also involved in the camouflage. 14A.
[Dr Heinz Peter Longerich]
Yes. 15Q.
[Mr Irving]
They replaced the word "shooting" with the handwritten 16word "resettlement"? 17A.
[Dr Heinz Peter Longerich]
Yes. 18Q.
[Mr Irving]
Which is a rather pointless kind of change if it is 19possible for us years later to see both words written 20down? 21A.
[Dr Heinz Peter Longerich]
Yes. Obviously, this man was not very intelligent who did 22this. 23Q.
[Mr Irving]
In paragraph 2.4 you quite clearly give an example here 24where "Umsiedlung" is unambiguously used in its homicidal 25sense: "There are two pits there and groups of 10 leaders 26and men working at each pit relieving each other every two

. P-71

1hours". 2A.
[Dr Heinz Peter Longerich]
Yes, and ---- 3Q.
[Mr Irving]
So that is what you are talking about when you are talking 4about the context, in context like that there is 5undoubtedly no question? 6A.
[Dr Heinz Peter Longerich]
Yes, exactly. 7Q.
[Mr Irving]
The clarity is beyond dispute, and it would take a lunatic 8to say or to continue to argue that the word "Umsiedlung" 9there does not mean that, it does not mean killing? 10A.
[Dr Heinz Peter Longerich]
I agree. 11Q.
[Mr Irving]
But in the case of the key documents that we are looking 12at with Adolf Hitler, which is all that interests me 13really, we do not have that degree of clarity, do we? 14A.
[Dr Heinz Peter Longerich]
I think I would like to suggest we should look at the 15documents and then we could ---- I think I should not make 16these general statements, I think I should always refer to 17---- 18MR JUSTICE GRAY: I think particularly in the light of that 19question, if there is a document, and I do not have one in 20mind, where Hitler uses the word "umsiedeln" ---- 21MR IRVING: With that degree of clarity. 22MR JUSTICE GRAY: --- Then it would be helpful to put it to the 23witness. I do not recollect if there is one or there is 24not. 25MR IRVING: What I am suggesting is that there is no such 26document with that degree of clarity.

. P-72

1MR JUSTICE GRAY: Is there a Hitler document using the word 2"umsiedeln"? 3MR IRVING: I do not believe there is, my Lord, in which case 4---- 5MR JUSTICE GRAY: Then the point is academic. 6MR IRVING: Your Lordship will know that I do not attach much 7important for my purposes. I attach more importance to 8the words "Vernichtung" and "Ausrottung". 9MR JUSTICE GRAY: Let us move on to Vernichtung; we have done 10Aurottung. 11A.
[Dr Heinz Peter Longerich]
My list is not complete; it is just what I found. 12MR IRVING: In paragraph 3, page 3, we are dealing with section 133 now, Evakuieren. 14A.
[Dr Heinz Peter Longerich]
Yes. 15Q.
[Mr Irving]
You do incidentally accept that the word "Umsiedlung" 16referred equally sometimes to the westward movement of 17ethnic Germans? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
And similarly "Besiedlung" can be the resettlement, for 20example, we have a September 1942 document where Lublin is 21being besiedelt with Volksdeutschen? 22A.
[Dr Heinz Peter Longerich]
I will always say that I would like to prefer to see the 23document and not to speculate about this, but you may be 24right. 25Q.
[Mr Irving]
"Evakuierung" does not always mean the killing, does it? 26It does not always have homicidal context either, does it?

. P-73

1A.
[Dr Heinz Peter Longerich]
It always depends on the context. 2Q.
[Mr Irving]
Yes. It usually means deportation under rough conditions 3or sometimes? 4A.
[Dr Heinz Peter Longerich]
Sometimes, yes, it also, you know, there was a scheme for, 5what is the expression, Luftkriegsevakuierung ---- 6THE INTERPRETER: The evacuation from air raids. 7A.
[Dr Heinz Peter Longerich]
In the context of air war, this was also the official 8term. So it could be used in a different context. 9MR JUSTICE GRAY: I think you are really agreed about 10Evakuierung, that ---- 11MR IRVING: On paragraph 3.2, we come to the 6th March 1942 12meeting where Eichmann is talking about the evacuation of 13the Jews to the East. 14A.
[Dr Heinz Peter Longerich]
Yes. 15Q.
[Mr Irving]
The second and third line it says: "Further evacuation of 1655,000 Jews", and you conclude that they are being sent to 17Auschwitz, and they should, you quote a document there, 18the Reich's security. 19A.
[Dr Heinz Peter Longerich]
No, I do not conclude that these Jews on 26th were sent to 20Auschwitz. One should, to make it clear, it would have 21been better to start on 20th with a new paragraph. This 22is a completely different issue. 23Q.
[Mr Irving]
On 20th February, the Reich's Security Head Office issued 24guidelines on implementation of the evacuation of Jews to 25the East, Auschwitz Concentration Camp. 26A.
[Dr Heinz Peter Longerich]
Yes.

. P-74

1Q.
[Mr Irving]
And from that, you conclude that the evacuation of the 2Jews to Auschwitz is a homicidal meaning, is it? 3A.
[Dr Heinz Peter Longerich]
I think this is quite clear from the document that the 4people were sent to Auschwitz and ordered to kill them 5there. So the term evacuation then, particularly 6after 1941, could just mean the deportation to a point but 7it also could mean the deportation to this point plus the 8killings of the people there. So, I think these two 9interpretations are possible after 1941. 10Q.
[Mr Irving]
Yes. I will come to this later on, either today or 11tomorrow, are you familiar with the Ahnert document, the 12deportation from France? 13A.
[Dr Heinz Peter Longerich]
No. 14Q.
[Mr Irving]
We will come to that when the time comes. 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
But you are not saying that all the people deported to 17Auschwitz were killed. You accept that some were used for 18slave labour? 19A.
[Dr Heinz Peter Longerich]
I think we went through the history of the Auschwitz. It 20was a combination of a slave labour camp and extermination 21camp. 22MR JUSTICE GRAY: But I do not think, Mr Irving, that you are 23suggesting that, when guidelines are issued on the 24evacuation of Jews to the East (Auschwitz concentration 25camp), you are not suggesting, are you, that evacuation 26has a wholly non-homicidal connotation there?

. P-75

1MR IRVING: It can be either, my Lord. Here is one typical 2example where the context does not really help us. I am 3trying to establish that, from what we know, we do not 4know whether they were killed on arrival or whether they 5were put to work as slave labour as very large numbers or 6what. So that document does not really help us. 7A.
[Dr Heinz Peter Longerich]
May I comment on that. 8MR JUSTICE GRAY: Yes, of course. 9A.
[Dr Heinz Peter Longerich]
I think that we know, not from the document, but, of 10course, we have enough information about Auschwitz to 11establish that, because these are guidelines; the general 12picture of what happens to Jews who were deported to 13Auschwitz after February 1943. So I think we could 14establish the context if we want to do so, but the 15selections and about sending people to gas chambers 16I think we have this information, and from this, I would 17then take this information and say that actually this 18makes it, I think, almost clear that the term evacuation 19here could include the killing of the people. 20MR IRVING: In fact, it means exactly what it says that has 21been evacuated to Auschwitz. 22A.
[Dr Heinz Peter Longerich]
I think we could, in a way, extend our knowledge and go 23into this day of Auschwitz, and it is not that this is a 24dark area ---- 25Q.
[Mr Irving]
This is not the time or place for that. 26A.
[Dr Heinz Peter Longerich]
So, we could do research and I think that, in the end, we

. P-76

1could come to the conclusion that this, in general, meant 2the extermination of the people in the camp at Auschwitz. 3Q.
[Mr Irving]
If I refer to the previous sentence beginning: "A report 4of 26th December", in which the head of the police force 5Saliter reported in detail about his experiences 6accompanying and supervising the transport of 1,007 Jews 7from the Rheinland to Latvia, is an entire report on the 8of evacuation of Jews to Riga, is that right? 9A.
[Dr Heinz Peter Longerich]
Yes. 10Q.
[Mr Irving]
In December 1941, what happened to these Jews who were 11deported to the Riga at that time? 12A.
[Dr Heinz Peter Longerich]
At this time, the Jews were actually sent to ghettoes or 13to camps. 14Q.
[Mr Irving]
To the Jungfernhof camp? 15A.
[Dr Heinz Peter Longerich]
To the Jungfernhof camp or to the ---- 16Q.
[Mr Irving]
So they were not massacred on arrival, then? 17A.
[Dr Heinz Peter Longerich]
Most of them were not massacred on arrival. 18Q.
[Mr Irving]
What conclusion do you draw from the use of the word 19evacuation there, then? 20A.
[Dr Heinz Peter Longerich]
Here, it says that the Jews -- I am trying to be cautious 21-- it says here that the Jews are going to be deported to 22Riga, and the document does not say that the Jews are 23exterminated on the spot. There is actually one reference 24in the Saliter report, where Saliter says that the 25collaborators, if I may call them so, in Latvia were quite 26astonished to see the Jews here because they said that you

. P-77

1can Ausrotten them yourself in Germany. But I think they 2were probably a little bit ahead at this time and in this 3context, I could not say that the word evacuation would 4necessarily include the killing of the people who were 5sent to this place. 6Q.
[Mr Irving]
Dr Longerich, we have actually seen a number of documents 7over the last weeks from this December 1941 period, 8indicating that these trainloads from the Reich to Germany 9carried provisions and equipment for their first weeks in 10there camp on arrival there. So the evacuation here, 11would you accept, does actually mean evacuation then and 12not necessarily anything more sinister? 13A.
[Dr Heinz Peter Longerich]
This is what we call the second wave of deportations. 14This was about 21 trains to Riga and about, I think, seven 15or eight trains to Minsk which happened between November 161941 and February 1942, except the six trains where the 17people were shot on the spot in Kovno and in Riga, except 18these six trains where the majority of these people 19actually were not shot on the spot but they survived a 20couple of months, most of them, and they were provided 21with all kinds of things, with tools and so on, from the 22Jewish communities because they, some of them, maybe even 23the majority, I do not know, some of them may actually 24have thought that they were some sort of pioneers who were 25sent to the East. So I think this idea to provide them 26with tools and so on also includes a moment of an element

. P-78

1of deception, giving them the idea that they actually can 2start a new life somewhere in the East. 3Q.
[Mr Irving]
Do you have any proof for that. This is an important 4point, I think. Do you have any proof that this was an 5element of deception in inviting them it take 6their appliances with them? 7A.
[Dr Heinz Peter Longerich]
I think that the fact that 6,000 people were shot on the 8spot gives you an idea there was a kind of, you know, a 9kind of juxtaposition between the provision of these 10trains and actually what happened to those people. If 11I can explain this. 12Q.
[Mr Irving]
I do not want really get into the police decodes business 13here, my Lord, because I think we will stick to the 14meaning of the words. 15MR JUSTICE GRAY: The cross-examination is notionally to do 16with the translation of words. 17MR IRVING: It is, entirely. 18MR JUSTICE GRAY: The trouble is you are chasing some of the 19uses. I understand why, Mr Irving; it is not a criticism 20of you, but the result is that it is a little bit 21scattered this cross-examination, and it is not a 22criticism. 23MR IRVING: I have two ways of doing it. Either I can follow 24my own plan or I can follow his own very useful glossary 25which he has provided for us, and as we all have the 26glossary, I think it is more useful if I follow his

. P-79

1paragraphing rather than introduce yet further confusion. 2But I am taking large leaps and bounds through it. 3MR JUSTICE GRAY: Yes. You have been confronted with the 4glossary and I suppose you have to really to deal with it. 5MR IRVING: Well I hope that is not implied criticism of my 6dealing with it. 7MR JUSTICE GRAY: It is not a criticism at all of you, Mr 8Irving, no. 9MR IRVING: But if the Defence does seek to rely on these 10meaning of these words, then I have to try to shoot them 11down. 12MR JUSTICE GRAY: Yes, I know. Well, take your own course. 13MR IRVING: Paragraph 3.3, the evacuation to the Lodz ghetto 14---- 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
Which was referred to in the Gestapo report of June 9th. 17A.
[Dr Heinz Peter Longerich]
Yes. 18Q.
[Mr Irving]
In fact, the stages of the evacuation make it quite plain 19that were not actually being evacuated to their death, so 20they were initially evacuated somewhere else. 21A.
[Dr Heinz Peter Longerich]
Yes, but it is ---- 22Q.
[Mr Irving]
They were transported to the special command. 23A.
[Dr Heinz Peter Longerich]
Yes, but it is clear from, if you look at the following 24document, it is clear that they were deported to the 25extermination camp Chelmno. The Sonderkommando is the 26Sonderkammandolange which actually was responsible for the

. P-80

1Chelmno extermination camp and the gas used there. 2Q.
[Mr Irving]
Abschieben, which is No. 4, carries only the meaning of 3deport really, does it not, or does it ----? 4A.
[Dr Heinz Peter Longerich]
This is the original meaning, I think. 5Q.
[Mr Irving]
Yes. Goebbels, for example, in his 27th March 1942 entry, 6talks about the Abgeschobene Juden, of whom 60 per cent 7would probably be liquidated. 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Irving]
Which implies that the Abschiebung, the deportation, was 10not the killing, that was just what they used what came 11first. 12A.
[Dr Heinz Peter Longerich]
You might be right in this case, but it is clearly said in 13his document what happened, so I think one of the key 14documents as far as Holocaust is concerned. 15Q.
[Mr Irving]
We are now on No. 5, which is Vernichtung. 16A.
[Dr Heinz Peter Longerich]
Yes. 17Q.
[Mr Irving]
In other words, abschieben is not a very important word in 18this particular argument, would you agree? 19A.
[Dr Heinz Peter Longerich]
I think that, in a kind of hierarchy, I would not put it 20on the top. 21Q.
[Mr Irving]
Yes. Vernichtung is, however, quite important, is it 22not? 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
You have quoted in 5.1, the Langenscheidt version of the 25word, as destroy, annihilate or exterminate, presumably in 26that order.

. P-81

1A.
[Dr Heinz Peter Longerich]
Yes. 2Q.
[Mr Irving]
It is really destroying a thing, is it not, or if you can 3regard a group of people as a thing, then it is destroying 4a group of people? 5A.
[Dr Heinz Peter Longerich]
If you look at the group of people as a thing then, if you 6make this ---- 7Q.
[Mr Irving]
For example, Judentum is a body of Jews, a community of 8Jews, is it not? 9A.
[Dr Heinz Peter Longerich]
Again, I think that we have enough examples to discuss it 10with reference to a document. We do not have to speculate 11about the possible ways the terminology was used. 12MR JUSTICE GRAY: I quite agree. 13MR IRVING: You refer to Klausewitz? 14A.
[Dr Heinz Peter Longerich]
Yes. 15Q.
[Mr Irving]
As defeating the enemy, you destroy the enemy? 16A.
[Dr Heinz Peter Longerich]
Yes. He is referring to, I think, an enemy army. So he 17is not referring just to people; he is referring, well, to 18an organization, and he is making it quite clear that the 19term "vernichtung" could mean, well, it could mean, as he 20said, annihilation of the enemy forces either by death or 21by injury or any other ways, either completely or merely 22to such an extent that the enemy no longer has the will to 23continue the fight. So I am trying to illustrate here 24that if the term "vernichtung" refers to an organization, 25it can have the meaning, you know, following Klausewitz, 26to kill all of them, to kill part of them, but basically

. P-82

1to make sure that the organization, as such, is not able 2to exist any more as an organization. 3Q.
[Mr Irving]
You could bankrupt somebody and he would be destroyed, 4could you not? 5A.
[Dr Heinz Peter Longerich]
Yes, you can make all other kinds of connotations. 6Q.
[Mr Irving]
Take the army prisoner ---- 7MR JUSTICE GRAY: It all depends on the context. 8A.
[Dr Heinz Peter Longerich]
Yes, you can make all kinds of combinations, but I think 9the most interesting, I mean if I may suggest that the 10most interesting case is of course when it refers to the 11vernichtung of people, not of an organization, of Judentum 12but of Jews, then I think it becomes clear what the term 13actually meant. 14MR IRVING: You have referred to Adolf Hitler's speech of 15January 30th 1939 ---- 16A.
[Dr Heinz Peter Longerich]
Yes. 17Q.
[Mr Irving]
--- in this context where he uses the word "vernichtung"? 18A.
[Dr Heinz Peter Longerich]
Yes, 5.6, footnote. 19Q.
[Mr Irving]
We do not have the exact quotation. 20A.
[Dr Heinz Peter Longerich]
Unfortunately not. 21Q.
[Mr Irving]
But the sense is, he said: If international finance Jewry 22once more succeeds in launching a new world war, then it 23will end not with the destruction of the European people, 24but with the destruction of, is it Judentum? 25A.
[Dr Heinz Peter Longerich]
Well, I have the quote in the first report. 26MS ROGERS: 38.

. P-83

1A.
[Dr Heinz Peter Longerich]
38. Shall I read this again? 2MR IRVING: I think it is an important passage. 3MR JUSTICE GRAY: Yes, perhaps you should in that case. 4A.
[Dr Heinz Peter Longerich]
I will only read the second -- well, I should read the 5whole passage: "In my life I have often been a prophet and 6was generally laughed at. During my struggle for power it 7was mostly the Jewish people who laughed at my prophecies 8that I would some day assume the leadership of the state 9and thereby of the entire folk, and then among many other 10things achieve a solution of the Jewish problem. 11I believe that in the meantime the then resounding 12laughter of Jewry in Germany is now choking in their 13throats. Today I will be a prophet again. If 14international Jewry within Europe and abroad should 15succeed once more in plunging the people's into a world 16war, then the consequence will be not the Bolshevization 17of the world and therewith a victory of Jewry, but on the 18contrary the annihilation of the Jewish race in Europe." 19 So "Jewry" is here in the German original 20Judentum, and the annihilation is the vernichtung, 21annihilation of the Jewish race in Europe. 22MR IRVING: Yes. The words "on the contrary" you just 23interpolated that. They are not in the original, are 24they. 25MR JUSTICE GRAY: "Sondern". 26MR IRVING: Sondern, it just means "but"?

. P-84

1A.
[Dr Heinz Peter Longerich]
But, yes. 2Q.
[Mr Irving]
It is the word "but" that comes in after a negative, is it 3not, as in French? I am going to draw your attention to 4the fact that this speech is on January 30th 1939? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
Had not a few days earlier Adolf Hitler through Hermann 7Goring as head of the four-year plan, appointed Reinhardt 8Heydrich to set up an agency to speed the emigration of 9the Jews from Germany? 10A.
[Dr Heinz Peter Longerich]
Yes. That is true, yes. 11Q.
[Mr Irving]
Yes. That was just four our five days previously, was it 12not, or about two weeks previously, something like that? 13It was one of the consequences of the Kristallnacht? 14A.
[Dr Heinz Peter Longerich]
Yes. Shall I explain the context? 15Q.
[Mr Irving]
Was that genuine or was that camouflage? 16A.
[Dr Heinz Peter Longerich]
Sorry? 17Q.
[Mr Irving]
Was the setting up of the Heydrich agency genuine or 18camouflage? 19A.
[Dr Heinz Peter Longerich]
I think this was at this stage genuine, but I think I have 20to explain the background, if you do not mind. 21MR JUSTICE GRAY: Yes. 22A.
[Dr Heinz Peter Longerich]
You know there were international negotiations going at 23this time between the so-called international government 24for refugees and the German Government represented by 25Hischaft. So the idea was that actually one could, you 26know, force world Jewry, as the Nazis perceived it, to pay

. P-85

1for the emigration of the Jews from Germany. In my 2interpretation I think they really thought this was a 3serious idea, a serious plan, that one could actually let 4them pay for the emigration of 400,000 Jews from Germany. 5So I think we have to look at Kristallnacht in this 6context, because I think the policy of the Nazis was to 7start a policy of terror against the Jews, to terrify them 8to leave the country, but also to force the Western powers 9actually to give in and to support this emigration 10programme. I think the speech has to be seen in this 11context. It is a threat, it a very violent threat: Look, 12if you don't agree and if we are getting in a kind of 13dispute again and if this dispute again will lead to 14another world war, then of course the life of the Jews in 15Europe is threatened, we are threatening the life of 16them. So if you look at the context they were, on the one 17hand, planning and preparing a programme for emigration, 18but on the other hand they were looking at the 19consequences if this programme would fail and if they 20would be involved in a military conflict with the Western 21powers again. 22 So if you threaten somebody, you know, it is a 23possibility. The whole idea I think of, well, threatening 24people is that you, in a way, leave a kind of uncertainty 25what you actually will do with the people you are 26threatening.

. P-86

1MR IRVING: I am sorry, did you want to say anything else? 2No. Would you regard this speech by Adolf Hitler as being 3a further twist to the Jewish arm, saying: "Get out while 4you can"? 5A.
[Dr Heinz Peter Longerich]
I think the motive behind the speech, there are various 6motives behind the speech, and one motive is clearly to 7threaten German Jews to leave the country as soon as 8possible. This is one of the motives behind the speech. 9MR JUSTICE GRAY: On what matters, which is what "vernichtung" 10means in that context ---- 11A.
[Dr Heinz Peter Longerich]
Yes. 12Q.
[Mr Justice Gray]
You say it does mean extermination or extirpation? 13A.
[Dr Heinz Peter Longerich]
I actually said here in the text "annihilation". You 14know, historians are debating this question. Some of my 15colleagues would say this is clear, Hitler actually at 16this stage had a clear programme to kill European Jews. 17I am not sure. I think the motives behind the speech are, 18there were different motives between the speech. It is a 19violent threat. It includes the possibility to kill the 20Jews in Europe, but I am not sure whether, you know, 21actually one can interpret this as a kind of programme 22which was already there. 23MR IRVING: What possible proof is there for the fact that 24Adolf Hitler had at this time, at the beginning of 1939, a 25programme or a plan or intent to liquidate the Jews of 26Europe or anywhere else?

. P-87

1A.
[Dr Heinz Peter Longerich]
The historians who would take this line would argue the 2events which followed to actually give us a kind of clue 3that Hitler probably had this plan at a very early stage. 4I do not agree with this view. I think he still, you 5know, was not sure whether he preferred emigration or 6whether he was going to the next step and actually 7envisaging, was actually trying to envisage what would 8happen in a case of a war. So I think it is a kind of a 9watershed here. 10Q.
[Mr Irving]
Is he effectively saying: "We will hold the Jews 11hostage"? 12A.
[Dr Heinz Peter Longerich]
I think this is the message. There are various motives 13behind the speech. The fact that he is referring here to 14a world war, not simply to a war, a war against Poland, 15let us say, but a world war, which implies the involvement 16of the Western powers. I think this is a threat against, 17the Western powers against Great Britain, in particular 18against the United States. But this speech is really open 19for interpretation. I cannot prove at this stage that 20Hitler had a programme, a blueprint to kill European Jews 21during the next years. I think it would go too far to 22draw this conclusion from this speech. It is definitely a 23very violent threat. It is three months after 24Kristallnacht, and actually I think one has to bear this 25in mind that, you know, it is saying we could actually 26repeat Kristallnacht on a much, much wider scale. I think

. P-88

1something like is implied here. 2MR JUSTICE GRAY: Mr Irving, I am conscious that time is 3passing and we are spending huge amounts of time on the 4meaning of these various words. In a way you have been 5rather pushed into doing it because of the form of the 6glossary, but it does not seem to me terribly helpful all 7this, because it all depends, and Dr Longerich's last 8answer reveals, that exploring what the context of a 9document is can be quite a complicated exercise. 10MR IRVING: I agree, my Lord, but I hope I am gradually 11bringing it home to your Lordship that when Adolf Hitler 12is concerned, which is the person I am largely concerned 13with, we are all at sea and anyone can draw whatever 14conclusion they want. 15MR JUSTICE GRAY: We are at sea in 1939. I am not so sure 16about 1941 and 1942. 17MR IRVING: Which I hope we will reach in the course ---- 18MR JUSTICE GRAY: Well, let us move on. 19MR IRVING: In that case I will not draw attention to what he 20said two days previously. 21MR JUSTICE GRAY: No, I think 41 and 42 is the time, when the 22shooting started on the Eastern Front, paragraph 5.7 23maybe. 24MR IRVING: I was up to 5.8 already. 25MR JUSTICE GRAY: Good. 26MR IRVING: At 5.8 you refer to the Goebbels diary entry, Adolf

. P-89

1Hitler speech? 2A.
[Dr Heinz Peter Longerich]
Yes. 3Q.
[Mr Irving]
To the Gauleiters on December 12th 1941? 4A.
[Dr Heinz Peter Longerich]
Yes. 5Q.
[Mr Irving]
Here the reference is, well, actually the reference is 6not, the "vernichtung" does not come in a speech; it comes 7in the second part, in the Hans Frank diary four days 8later. 9A.
[Dr Heinz Peter Longerich]
According to the Goebbels diary he says "vernichtung" in 10this speech, and again the full reference is in, the 11translation is in the other report, in the first report 12which is in chronological order so we should find it. 13MR JUSTICE GRAY: 61? 14A.
[Dr Heinz Peter Longerich]
Yes. There is footnote 156, so if we look at the German 15text in the first report, page 61, then we have the 16translation I think in both. 17MR IRVING: That is in fact harking back to precisely that 18speech, is it not. 19MR JUSTICE GRAY: It is completely circular. 20A.
[Dr Heinz Peter Longerich]
Yes. 21MR IRVING: It is exactly the same. 22A.
[Dr Heinz Peter Longerich]
Yes, he did this a lot of times. He always came back to 23this speech. I think he have five or six or more examples 24where Hitler is actually referring to this prophecy, 25particularly at this time. It is not only on 12th 26December; it is also on 1st January, 30th January and 24th

. P-90

1February. He is always giving the same text. On 21st 2February he is actually replacing the word "vernichtung" 3by "ausrotten". So he is actually saying, he is 4indicating that things become actually more violent and 5more threatening. 6Q.
[Mr Irving]
You then look at what Hans Frank said on December 16th? 7A.
[Dr Heinz Peter Longerich]
Yes. So we are back in the glossary? 8Q.
[Mr Irving]
Yes, back in the glossary, paragraph 5.8. 9A.
[Dr Heinz Peter Longerich]
Yes. 10Q.
[Mr Irving]
Is it plain that the word "vernichtung" as used by Hans 11Frank is unambiguously referring to liquidation there? 12Immediately before the passage you quote, has not Frank 13told subordinates that a great Jewish emigration is about 14to begin, meaning the Jews of the German government are 15going to be deported and adopted by the Soviet Union? 16A.
[Dr Heinz Peter Longerich]
Yes, again I would prefer to see the text here. I do not 17know who has the full. 18MR RAMPTON: I think we probably need the new file. That is 19much the best way of doing it. 20MR JUSTICE GRAY: I am just wondering where we get with this. 21This is Frank putting a gloss on Hitler had said in 1939. 22We have looked at what Hitler said in 1939. 23MR RAMPTON: No, my Lord, I think the case is Frank is putting 24a gloss, if that be the right word, on what Hitler said on 2512th December 1941. 26MR JUSTICE GRAY: Do we need to trouble with what Frank says?

. P-91

1MR RAMPTON: The witness makes the point, and indeed Mr Irving 2accepts, that the understanding which Frank had of what he 3had been told by Hitler in Berlin was quite unequivocal. 4It was about physical liquidation. 5A.
[Dr Heinz Peter Longerich]
Yes. He came back from Berlin -- it is four days after 6Hitler's speech -- saying he had discussions in Berlin 7and he is referring to this discussion. I think it is 8fair to assume, because Frank was as Reichsleiter present 9at the Reichs and Gauleiter meeting, so it is fair to 10assume that he is referring to this speech and may be 11other discussions they had. 12MR JUSTICE GRAY: I thought he was referring back to 1939. 13A.
[Dr Heinz Peter Longerich]
Yes, but if you look at the ---- 14MR RAMPTON: I think, my Lord, it would honestly be helpful 15because what we have done in this file is to put in fact a 16long translation provided by Professor Browning against 17the German text. Would you turn to 172, first of all? 18That is the English of Professor Browning. . 19A.
[Dr Heinz Peter Longerich]
Where will I find that? 20MR JUSTICE GRAY: It is called N1. It is also in another file 21but this is probably the best place. 22MR RAMPTON: Do not worry about the other file. N1 is the one 23you need. I hope this should be a long paragraph in 24English indented. My Lord, may I ask the witness whether 25that is what he has? 26A.
[Dr Heinz Peter Longerich]
Yes, I have got that.

. P-92

1MR JUSTICE GRAY: Yes. 2MR RAMPTON: If one turns to page 6 in a bold crayon, 178, one 3finds a third of the way down the page the words "mit den 4Juden". 5A.
[Dr Heinz Peter Longerich]
Yes. 6MR RAMPTON: That I think is the passage we are looking for. 7A.
[Dr Heinz Peter Longerich]
Yes. 8MR RAMPTON: I will leave it there. 9MR JUSTICE GRAY: Thank you very much, Mr Rampton. 10MR RAMPTON: I should add that it goes over the page to the end 11of a paragraph, the next paragraph beginning "Die 12ucheiner". 13A.
[Dr Heinz Peter Longerich]
Yes. 14MR JUSTICE GRAY: Yes. Mr Irving, have you got N1? Were you 15able to follow all that? 16MR IRVING: I am going with your Lordship's view that what Hans 17Frank's use of the word means is really not of much 18relevance, having gone to all that trouble. 19MR JUSTICE GRAY: The way it is put is, and just decide whether 20you want to ask a question, is that Frank had just come 21back from Berlin where he had heard Hitler speaking, so he 22is not harking back in all of what he says to 1939 but to 23four days before. 24MR IRVING: Yes. 25MR JUSTICE GRAY: I think the way it is put is that vernichtung 26is used fairly unambiguously in Frank's speech as a record

. P-93

1of what he had been told in Berlin. It is really that one 2phrase, is it not, Dr Longerich? "In Berlin we were told 3why all this trouble, we cannot use them in the Ostland or 4the Reichskommissariat either, liquidate them yourselves"? 5A.
[Dr Heinz Peter Longerich]
Yes. That is I think the main paragraph, the main 6sentence. 7Q.
[Mr Irving]
It may be that you do not want to cross-examine about 8that, Mr Irving? 9MR IRVING: Not really, because it is not the word vernichtung 10unfortunately. 11A.
[Dr Heinz Peter Longerich]
It is the words Juden vernichtung. That is in there, in 12the German text. (German spoken). The term vernichtung 13the term vernichtung is clearly in here. When he is not 14sure about the means how to vernichtung the people, he is 15saying we cannot liquidate, we cannot execute them, we 16cannot poison them, so what shall we do? 17MR IRVING: That is the problem we have with that particular 18passage, of course, my Lord, is it not Frank says earlier, 19we cannot poison them, we cannot shoot them. 20A.
[Dr Heinz Peter Longerich]
Yes. We are looking -- this is on page bold 7, second 21paragraph. So they are looking for a kind of solution, 22how to vernichtung the people. 23MR IRVING: Without shooting or poisoning them? 24A.
[Dr Heinz Peter Longerich]
Yes. Poisoning could be a possible method. They are 25looking for a kind of solution to this problem and then it 26is explained here that we will have a meeting in Berlin,

. P-94

1and this is obviously the Wannsee conference. Then it 2becomes clearer what would happen in the 3Generalgouvernement. 4Q.
[Mr Irving]
If you went back to the Klauserwitz example and somebody 5said to a German general, we have Eisenhower's armies in 6front of us, we cannot shoot them, we cannot poison them, 7how are we going to destroy them? The answer is, cut off 8their water supply, cut off the power, deprive them of the 9shipping lines, the oil. There are all sorts of ways of 10destroying an enemy. 11A.
[Dr Heinz Peter Longerich]
That is why I am trying to explain how difficult it is to 12make comparisons because clearly von Klauserwitz is 13referring to an army, and in your example you refer to an 14army, but here it is about the Jews. 15Q.
[Mr Irving]
An enemy? 16A.
[Dr Heinz Peter Longerich]
An enemy, but the Jews are the Jews. This is the people, 17the human beings, and if I destroy, vernichtung, human 18beings, and I discuss then the methods, whether I should 19liquidate them, execute them or whether I should poison 20them, I think then the context is pretty clear. There is 21not much room for interpretation, I think. 22Q.
[Mr Irving]
Dr Longerich, it is even clearer than that because he 23says, we cannot shoot them and we cannot poison them. 24A.
[Dr Heinz Peter Longerich]
Yes, because they have not been told from Berlin what 25method they should use. Then, if you into the Wannsee 26protocol, actually the suggestion comes from von Below,

. P-95

1they had the Secretary of State, "We could like to deal 2with the Jews on the spot, we do not want to send them to 3the East, we would like to do it here". Then it goes on 4in the Wannsee protocol. The various methods were 5discussed how to solve the problem. Then they were 6discussing what to do, poisoning, gassing, probably 7executions. This is preWannsee. He was sure that they 8were going to vernichtung the Juden, because it came back 9from Berlin and heard the speech, but the method was 10unclear. 11Q.
[Mr Irving]
You are not suggesting, although I am sure you quite 12accidentally gave the opposite impression, that in the 13Wannsee protocol there is any reference to killing at all, 14is there? 15A.
[Dr Heinz Peter Longerich]
I do not know whether we will go to the Wannsee conference 16in more detail. 17MR JUSTICE GRAY: The problem with all of this is that it is 18not Mr Irving's fault at all, because he has been 19confronted with this glossary and I can understand why he 20is going through it, but to me it is unhelpful, this whole 21exercise. We are coming across odd documents from 39 or 2235 or 43. 23MR IRVING: Rather the same thing happened with the previous 24witness, my Lord. We came across topics that the witness 25urgently wanted to talk about and which no doubt will get 26raised later on.

. P-96

1MR JUSTICE GRAY: I think it is better to look at these words 2when we come across them in the context of examining the 3substantive issues rather than having a kind of linquistic 4sequence of questions. 5MR IRVING: That would be the other way of slicing the same 6cake. 7MR JUSTICE GRAY: I know it would. I say again -- it is not 8intended critically of you at all -- that darting from 9one document to another is not I think particularly 10helpful. 11MR IRVING: I am very rapidly going through the remaining part 12of the glossary to see if there are any important points 13to take. The fact that Robert Lie used a word a certain 14way does not mean to say necessarily that that was the 15standard meaning of the word? 16A.
[Dr Heinz Peter Longerich]
I am only referring to Lie. He was one of the top Nazis 17and he used the term in a quite open way. I find our 18discussion quite interesting but ---- 19Q.
[Mr Irving]
Very well. In that case that finishes the with the 20glossary I think. I may wish to come back to it. Dealing 21now with your first report, Dr Longerich, page 10, you say 22there in your opening sentence that there can be no doubt 23that Hitler's behaviour during his entire political career 24was characterised radical anti-Semitism. 25A.
[Dr Heinz Peter Longerich]
Yes. 26Q.
[Mr Irving]
Was he always an anti-Semite, in your view, or did it come

. P-97

1upon him in his youth? 2A.
[Dr Heinz Peter Longerich]
I think this way of radical anti-Semitism, which means 3that he wants to basically remove the Jews from, let us 4say, German soil, I think this is a product of the First 5World War and appeared immediately after the First World 6War. Other historians would argue that actually he learnt 7this in Vienna, but I think one has more to emphasise. 8Q.
[Mr Irving]
There have been all sorts of weird theories, have there 9not, about where it came from? 10A.
[Dr Heinz Peter Longerich]
Yes, there are all kinds of theories. I think we are on 11safer ground if we look at the period after the First 12World War. 13Q.
[Mr Irving]
Were all the top Nazi leadership equal in their 14anti-Semitism, or were some more anti-Semitic than 15others? Were some more motivated than others? 16A.
[Dr Heinz Peter Longerich]
Quite clearly some more anti-Semitic than others. 17Q.
[Mr Irving]
Some were more homicidally anti-Semitic than others? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
Obviously you have worked for 20 years now in the records 20so you must have gained some impression that you can tell 21us about, the kind of league table of anti-Semitism. 22Would Martin Bormann be high up the list of anti-Semitism 23as an active anti-Semite? 24A.
[Dr Heinz Peter Longerich]
Absolutely, yes. Definitely. 25Q.
[Mr Irving]
Dr Josef Goebbels, would he be more or less anti-Semitic 26than Bormann?

. P-98

1A.
[Dr Heinz Peter Longerich]
I have never thought about a kind of hierarchy, but 2I think, if you look at the top Nazis, I think you can 3fairly say that radical anti-Semites, people who wanted to 4remove by any means the Jews from Germany, I think you 5would count among them Hitler, Himmler, Goebbels, Bormann, 6I think, and some others. 7Q.
[Mr Irving]
Hermann Goring, for example, was always getting in trouble 8because he had Jewish friends, did he not? 9A.
[Dr Heinz Peter Longerich]
Yes, but the fact that one has Jewish friends does not 10necessarily exclude that one can be an anti-Semite or even 11a radical anti-Semite. I think probably Goring looked at 12this more from a kind of political or tactical point of 13view. I am not sure. I think the anti-Semitism of Goring 14and his role in the Final Solution has not been fully 15researched. That is all I can say to that. 16Q.
[Mr Irving]
Goebbels was the real mover and shaker, was he not? He 17was the propagandist, he was the little poison dwarf, the 18evil genius? 19A.
[Dr Heinz Peter Longerich]
He was definitely a radical anti-Semite, and he was trying 20to push forward anti-Semitic policy, this is right, but 21I would not make a kind of hierarchy where I would place 22Goebbels at the top. 23Q.
[Mr Irving]
The reason why I am asking this is this. Goebbels, for 24example, would never have dreamed of employing a Jew on 25his staff or a half Jew on his staff, would he? I do not 26think he did.

. P-99

1A.
[Dr Heinz Peter Longerich]
I cannot say anything about his dreams, but I think he did 2not, as far as I know. 3Q.
[Mr Irving]
That is an English expression. Adolf Hitler of course did 4have some half Jews on his staff, did he not? 5A.
[Dr Heinz Peter Longerich]
I do not know. I cannot recall any names. Hitler? 6Q.
[Mr Irving]
Yes. His private chauffeur, Emile Morris. When it turned 7out that Emile Morris was Jewish, did not Hitler protect 8him and keep him on to the end? 9A.
[Dr Heinz Peter Longerich]
I cannot recall this. 10Q.
[Mr Irving]
Do you know Peter Hofmann, Professor Peter Hofmann? 11A.
[Dr Heinz Peter Longerich]
Yes. 12Q.
[Mr Irving]
He is a well-known Canadian German historian, is he not? 13A.
[Dr Heinz Peter Longerich]
Yes. 14Q.
[Mr Irving]
Have you read his book, Hitler's Personal Security? 15A.
[Dr Heinz Peter Longerich]
I know the book but I cannot recall this detail. I simply 16do not know. 17Q.
[Mr Irving]
Does it not strike you as odd that an anti-Semite like 18Hitler would not mind having a Jewish chauffeur, Emile 19Morris? 20A.
[Dr Heinz Peter Longerich]
I cannot comment on this story. I do not know whether it 21was an established fact that Morris was a Jew. I cannot 22comment on that. Again I would say, if you look into the 23history of anti-Semitism, the greatest anti-Semites had 24sometimes Jewish friends. They would say, well, this is 25my friend, he is an exception, he is not like others. 26This is a typical stereotype.

. P-100

1Q.
[Mr Irving]
You are damned if you do and damned if you do not, 2effectively? 3A.
[Dr Heinz Peter Longerich]
It is a typical stereotype. I do not think one can draw 4major conclusions from the fact that somebody protected a 5Jew or had Jewish friends. 6MR JUSTICE GRAY: Just pause a moment, Dr Longerich. 7MR RAMPTON: Can I say something? I am not criticising 8Mr Irving in the very least for having gone through that 9glossary, and he did it really rather quickly, but I am a 10bit concerned now because Mr Irving conceded one question 11and answer to the effect, I think, that Hitler was from 121919 onwards a profound anti-Semite and that anti-Semitism 13was one of the important planks of Nazi ideology. 14MR JUSTICE GRAY: So, in the early years you say that this is 15really not an issue? 16MR RAMPTON: I have made it specific. From 1919 onwards and 17that anti-Semitism became an important plank of Nazi 18ideology or policy call it what you like. 19MR JUSTICE GRAY: Adding the rider that, as far as Hitler 20personally was concerned, he had other things on his mind 21from about the invasion of Russia. 22MR RAMPTON: He may have had other things on his mind. Being 23an anti-Semite is not exclusive of other things. 24MR JUSTICE GRAY: No, but I think Mr Irving's case, and he will 25correct me if I am wrong, is that anti-Semitism was not 26really something that was concerning Hitler from -- am

. P-101

1I right about this -- about 1941 onwards, because he was 2fairly preoccupied. 3MR RAMPTON: No. He said from the time he came to power. From 41933. 5MR JUSTICE GRAY: You tell me, Mr Irving. Have I misunderstood 6your case? 7MR RAMPTON: I have misunderstood Mr Irving's concession, if 8that be right. 9MR IRVING: My Lord, my general impression is that Adolf Hitler 10abandoned that particular plank once he came to power. It 11had been very useful for getting him into power but, once 12he was an absolute dictator, he did not need it any more 13and it bulked less large. 14MR JUSTICE GRAY: The point Mr Rampton makes is do we need to 15spend very long exploring anti-Semitism in the 30s, given 16that you accept that he was a radical anti-Semite over the 17entirety of that period? 18MR IRVING: The question is whether he was a cynical 19anti-Semite and used it in the same way that an Enoch 20Powell might use immigration as a means of establishing a 21political position, or whether he was profoundly 22viscerally anti-Semitic. 23MR JUSTICE GRAY: Which option are you going for? 24MR IRVING: I am going for the cynical version, my Lord. 25MR JUSTICE GRAY: So he was not really an anti-Semite, it was 26just a political gambit?

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1MR IRVING: He was when it served his purpose. He was a beer 2table anti-Semite. He used it to whip up support, but in 3private, and this is what counts, his state of mind was 4slightly different, which is what I was trying to elicit 5from just one or two episodes of his own---- 6MR JUSTICE GRAY: I find that slightly difficult difficult to 7reconcile with your acceptance earlier on in this trial 8that he was without qualification a rabid anti-Semite, at 9any rate in the 30s. 10MR IRVING: I would then say it is perfectly possible for him 11to have been like that originally and then drifted out 12when he no longer needed it, just as with Goebbels it was 13the other way round. Goebbels was originally viciously 14anti-anti-Semitic and wrote his letter to his girl 15friend---- 16MR JUSTICE GRAY: Do not let us worry about Goebbels. Can you 17put this point that you are now making in a general way to 18Dr Longerich? 19MR IRVING: Two more questions and then we will have it, I 20think. Adolf Hitler's dietary cook was also Jewish, 21Marlene Exener. 22MR JUSTICE GRAY: That is not putting it in a general way. 23MR IRVING: I was going to say -- well, is the answer do you 24know that or not? 25A.
[Dr Heinz Peter Longerich]
No. 26Q.
[Mr Irving]
If somebody maintained people like that on his private

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1staff, is it an indication that personally he had no 2real -- what is the word I am looking for -- distaste 3for Jews as individuals? 4A.
[Dr Heinz Peter Longerich]
I think I made my point. I think, if you look into the 5history of anti-Semitism, you cannot draw conclusions from 6these personal relationships, because the anti-Semite 7would always argue, well, this is an exception, this is 8not a typical Jew, this person is different. I remember 9vaguely these rumours that one or the other person was 10Jewish, or what they called half Jewish, but I do not 11think one can actually write a kind of history of Hitler's 12anti-Jewish policy on this basis. This might be the case, 13but it does not -- it is a well-known stereotype in the 14history of anti-Semitism, as I said. 15MR JUSTICE GRAY: Can I interrupt you rudely and just ask you 16the question which was the one I had in mind? Do you 17accept what Mr Irving is contending, that Hitler's 18anti-Semitism in the 1930s was not an expression of a 19genuine anti-Jewish feeling, but was simply a political 20gambit to enable him to achieve power? 21A.
[Dr Heinz Peter Longerich]
No, I do not think so. I do not agree. 22Q.
[Mr Irving]
Pursue it, if you want to, Mr Irving, but that was the 23general question I had in mind. 24MR IRVING: I would ask again the general question. If he was 25viscerally anti-Jewish and anti-Semitic, would he have 26tolerated Jewish members of his personal staff? Would he

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1have tolerated Field Marshal Milsch, who was a well-known 2half Jew? 3A.
[Dr Heinz Peter Longerich]
I think I made my point clear. As far as I see 4anti-Semitism -- my English runs out a little bit -- 5there is no contrast, no juxtaposition. I think this does 6not actually disturb my view. It does not surprise me. 7Q.
[Mr Irving]
OK. Just one final question to round off this context. 8In that little league table I was beginning to draw up of 9Himmler, Goebbels, Goring, Bormann, Lammers, Hitler, where 10would Hitler come on the anti-Semitism scale? Would he be 11above or below Dr Goebbels? Would he be more or less 12anti-Semitic? 13A.
[Dr Heinz Peter Longerich]
I would just say that Hitler was a radical anti-Semite 14like Goebbels. The degree of percentage, I cannot make a 15judgment about that. I do not know how one measures 16radical anti-Semitism. 17Q.
[Mr Irving]
Which way did the anti-Semitic current flow? From 18Goebbels to Hitler, or Goebbels to Hitler? 19A.
[Dr Heinz Peter Longerich]
If you look at this group of people, I think I would 20describe it as a consensus. It was a general radical 21anti-Semitic consensus among them and it is impossible to 22say. 23MR JUSTICE GRAY: I think we understand the difficulty you are 24in and I think, Mr Irving, you must move on. 25MR IRVING: If you had read the Goebbels diaries right through, 26would you be able to form an impression on who was making

. P-105

1the suggestions to whom, or who was just listening? 2A.
[Dr Heinz Peter Longerich]
Again, I would prefer to look then at certain 3passages. As a general view I think my interpretation is 4that there was a high degree of anti-Semitic consensus 5between Hitler and Goebbels, and of course Goebbels in his 6diaries, one of the motivations, motives, why Goebbels 7wrote the diaries is that he wanted to show, the diaries 8should present him as a very active energetic person. So 9of course, he is in a way the actor, and others actually 10are reacting to him. My general impression is that there 11was an anti-Semitic consensus among them. 12MR JUSTICE GRAY: Yes. 13MR IRVING: Can we now go to page 12 of your report, paragraph 141.4? 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
In general terms you are saying that, between the outbreak 17of war in summer 1939 and the middle of 1941, the Nazis 18were look for a territorial solution to the Jewish 19problem. 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Irving]
Is this commonly accepted or do most historians now accept 22that there was no homicidal plan? 23A.
[Dr Heinz Peter Longerich]
This is accepted, but I made a little comment there at the 24end, and I said, well, actually, if you look at the 25so-called territorial solution, one should actually say, 26and this is my argument, that this increasingly offers a

. P-106

1perspective of the physical end of the Jews in Europe. So 2I think the territorial solution, it was not meant that 3the Jews should actually come back from this reservation 4or whatever they planned, and they should stay there for 5300 years. I think, if you look seriously at this 6territorial solution, these plans had clearly a genocidal 7implication, but they were still plans. They were not 8carried out. 9Q.
[Mr Irving]
So that, although they were talking in terms of geography 10and moving them out beyond the pale, even then you suspect 11that they would really like to kill them? They were 12thinking in terms of killing? You want to have it both 13ways, really? 14A.
[Dr Heinz Peter Longerich]
I would come back to this phrase there is obviously a 15strong genocidal element in those plans, so they were 16considering among themselves the question how and whether 17the Jews would survive or they would not survive. 18Q.
[Mr Irving]
Are you talking about the European Jews here or the 19Russian Jews? 20A.
[Dr Heinz Peter Longerich]
I am talking about the European Jews. 21Q.
[Mr Irving]
But there is no actual document which indicates a 22homicidal intent. It is just that your feeling is they 23were talking geography but thinking in terms of bullets? 24A.
[Dr Heinz Peter Longerich]
I could expand on that. There are two arguments. First 25of all, if you look at the plans themselves, at the 26comments they made on the plans, I think you can come to

. P-107

1the conclusion that these so-called reservations would not 2offer sufficient means for existence to the Jews. On the 3other hand, I collected quite a number of comments from 4top Nazis, which actually made quite clear from the 5context that what they envisaged was that the Jews, the 6Jewry, Judentung, the Jews would actually not survive in 7the end this deportation to reservations. 8Q.
[Mr Irving]
They hoped they would perish in the process? 9A.
[Dr Heinz Peter Longerich]
They would perish and put to death by a combination of 10diseases, epidemics, simply insufficient means for 11survival, hard labour and things like that. 12Q.
[Mr Irving]
Dr Longerich, you appreciate there is a difference in 13intent there, just saying, "I want them to get out and who 14cares what happens to them when they are out"? 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
That is one thing, but that is not quite the same as 17saying a homicidal intent? 18A.
[Dr Heinz Peter Longerich]
Yes. I think that is to say very short, that is the 19difference between the idea to let them perish out there 20and to immediately kill them by executions or gas and so 21on. That is the difference. 22Q.
[Mr Irving]
I do not want to go right back to the 1920s, but you do 23rely in part on Mein Kampf, do you not? 24A.
[Dr Heinz Peter Longerich]
Yes, of course. 25Q.
[Mr Irving]
I have a copy of Mein Kampf here, one of these little 26things you collect over the years, given to me. I hasten

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1to add I have never read it. Am I right in saying that 2Adolf Hitler was not the only person whose hand is to be 3seen in Mein Kampf? In fact a number of other people 4wrote it with him, Rudolf Hess and others? 5A.
[Dr Heinz Peter Longerich]
I should say I read the book. I think it is a very 6interesting book. One should read it. Hitler dictated it 7to Hess. It is unclear. Some historians would argue that 8actually he helped to improve in a way the text, but 9I think the fact that Hitler's name is on the book 10indicates that he is responsible for every word in the 11book. I think also one recognizes of course his thoughts 12in the text. 13Q.
[Mr Irving]
Do you see a direct line then between what Adolf Hitler 14put his name to in Mein Kampf in 1923 or 1924 and what 15subsequently happened 20 years later? 16A.
[Dr Heinz Peter Longerich]
No. I think the policy developed gradually, but we have 17to take the fact into account that Hitler made very 18radical anti-Semitic statements as soon as the mid 20s. 19We cannot overlook this fact. 20Q.
[Mr Irving]
He made anti-Semitic statements in it? 21A.
[Dr Heinz Peter Longerich]
Yes, Mein Kampf. He spoke about putting 12 to 15,000 of 22these people to gas and so on. 23Q.
[Mr Irving]
They could be held under gas? 24A.
[Dr Heinz Peter Longerich]
Yes. He did not say that he was intending to kill 25European Jews, but he made some very, very interesting 26statements concerning the fate of the Jews.

. P-109

1MR JUSTICE GRAY: Mr Irving, this is only a suggestion. It 2seems me that the key phase really is when talk moved, as 3Dr Longerich says it did, from deportation to Madagascar 4or wherever else ---- 5MR IRVING: 1941 is the key year. 6MR JUSTICE GRAY: Yes, exactly. Do you think that is where 7your quarrel with Dr Longerich really starts, is it not? 8MR IRVING: This is absolutely true and that is why your 9Lordship will see that I am rapidly leafing through the 10pages which are heavily annotated by me, the 11Reichskristallnacht and so on. 12MR JUSTICE GRAY: I know it is a temptation, but if you can 13resist the temptation. 14MR IRVING: In the meantime we have dealt with the 15Reichskristallnacht. 16MR JUSTICE GRAY: I think you have. 17MR IRVING: I do not know what the law is here. If I do not 18traverse these matters here in court ---- 19MR JUSTICE GRAY: I have said this already. I think in the 20context of this case, if you have already cross-examined 21another expert on a particular topic, and you have 22certainly cross-examined Professor Evans on Kristallnacht, 23that is quite sufficient, unless Mr Rampton wants to 24persuade me otherwise, by way of putting your case, and 25you certainly do not need top traverse the same ground 26again with Dr Longerich. Mr Rampton, you do not disagree

. P-110

1with that? 2MR RAMPTON: No, I do not. Reichskristallnacht is mentioned in 3passing only in the first part of Dr Longerich's report. 4MR JUSTICE GRAY: I think the same applies really to the 5shooting by the Einsatzgruppen. 6MR IRVING: To much else, which is not a matter of great 7contention between us. 8MR JUSTICE GRAY: That is true. 9MR RAMPTON: I think it has gone really as an issue. 10MR JUSTICE GRAY: So really I think we are looking towards the 1140s in terms of pagination. 12MR IRVING: We are making rapid progress. For the remaining 13three minutes I will just have a quick look at page, 45 14please. On May 25th 1940 Himmler did put this document to 15Hitler on the plans for the East? 16A.
[Dr Heinz Peter Longerich]
Yes. 17Q.
[Mr Irving]
Was this again Plan Ost or was that another document? 18A.
[Dr Heinz Peter Longerich]
This was the future of the Frentfurgischer, as it was 19called in the text, the alien people. 20Q.
[Mr Irving]
Does not Himmler in this document say words to the effect 21that we cannot do what the Russians do, we cannot just 22liquidate them? 23A.
[Dr Heinz Peter Longerich]
Yes, the quote here is: "The Bolshevist methods of 24physically extirpation (Ausrottung) of a people because of 25inner conviction, as un-German and impossible". So he is 26distancing himself from ausrottung. In the same text he

. P-111

1says: "I hope to see that by means of the possibility of a 2large emigration of all Jews to Africa or to some other 3colony - that the concept of Jew will be fully 4extinguished". So I think we have take these 5two sentences into account. Distinguished but not 6ausrottung. 7Q.
[Mr Irving]
I just wanted to look at the fact that the word ausrottung 8in that document does not by itself mean killing, because 9Himmler had to add the word "physical" in font of it, did 10he not, so going to physically ausrottung them? 11A.
[Dr Heinz Peter Longerich]
Of course that is a possible interpretation, but sometimes 12in a document you make your position very clear by 13actually repeating the same meaning and adjective. 14Q.
[Mr Irving]
That is added emphasis, is it? 15A.
[Dr Heinz Peter Longerich]
Yes, you have to have a subject but you also add an 16adjective. 17Q.
[Mr Irving]
To make it unmistakable? 18A.
[Dr Heinz Peter Longerich]
Yes, exactly. 19Q.
[Mr Irving]
Because otherwise it could be mistook. 20A.
[Dr Heinz Peter Longerich]
Yes, and also probably you want to strengthen your point. 21People tend to repeat themselves. That is quite a common 22experience. If in the same document you make the same 23point twice or three times, it does not always, I think 24one cannot -- well, I stop here. Sorry. 25Q.
[Mr Irving]
Just like Adolf Hitler in that November 10th 1938 speech 26using the phrase "we do not need them"? He says it twice

. P-112

1in one sentence. 2A.
[Dr Heinz Peter Longerich]
Yes. 3Q.
[Mr Irving]
It does not add anything really? 4A.
[Dr Heinz Peter Longerich]
Yes, for example. 5Q.
[Mr Irving]
I see a smile from his Lordship. That was not the point 6I was hoping to make there. I would hate to go down just 7on that one sentence. That is the reason. Page 46 just 8for one minute. The Madagascar plan was quite feasible, 9was it not? 10A.
[Dr Heinz Peter Longerich]
In which sense feasible? 11Q.
[Mr Irving]
It could have housed them. The island is big enough. 12MR JUSTICE GRAY: The relevant question is they thought it was 13feasible? Whether they were right or not may not be here 14or there. 15MR IRVING: I was going to ask the witness. He is rather 16dismissive of the plan. 17A.
[Dr Heinz Peter Longerich]
In which sense feasible? You mean to provide a place 18where 4 million Jews could have a happy life? In this 19sense feasible? 20Q.
[Mr Irving]
Happier life. 21A.
[Dr Heinz Peter Longerich]
Or feasible in the sense of an SS police state, so to say 22a big prison, with a high death rate? In this sense 23I would say, yes, it was feasible. We have contemporary 24examinations about this problem. For instance, the Polish 25Jewish Commission which was sent to Madagascar in 37, they 26came back with a recommendation that, as one member put

. P-113

1it, Madagascar would offer a place for about 50 to 75,000 2people. The Jewish members of this Commission did not 3agree. They said 2,000 probably. So this is contemporary 4evidence we have. I would say clearly that I doubt that 4 5million Jews would have the chance to survive this, if 6I may say, excursion to Madagascar in 1940. 7Q.
[Mr Irving]
Dr Longerich, one final question before the adjournment. 8Are you aware that the population in Madagascar has 9increased from about 2 million to 13 million over the 10period? 11A.
[Dr Heinz Peter Longerich]
I looked it up because this was always said. 4 million in 1230s to 30 million indeed in the 1990s, yes. 13Q.
[Mr Irving]
So that kind of population could have been absorbed? 14A.
[Dr Heinz Peter Longerich]
Yes, within 50 years, with an infrastructure and so on, of 15course. Experience shows that. 16MR JUSTICE GRAY: Two o'clock. 17(Luncheon Adjournment)18(2.00 p.m.)19MR RAMPTON: My Lord, can I hand in my little note on the 20inadmissibility of expert witness statements? 21MR JUSTICE GRAY: Thank you very much -- yes, please. 22MR RAMPTON: I say no more about it. Yes. 23MR JUSTICE GRAY: Yes, Mr Irving? 24MR IRVING: Thank you. (To the witness): Dr Longerich, we had 25reached the middle of 1941 roughly and I think I am right 26in summarizing that there is no evidence up to 1941, the

. P-114

1middle of 1941, of any directives by Hitler to exterminate 2Jews, no order for a systematic extermination of the Jews 3that you are aware of by the middle of 1941? 4A.
[Dr Heinz Peter Longerich]
Well, if it comes to the preparation of Barbarossa, 5I would not agree. Before that -- at the moment I cannot 6-- probably you are right, I cannot recall something like 7that. 8Q.
[Mr Irving]
Yes, shall we have a look at the directives issued in May 91941 now? 10A.
[Dr Heinz Peter Longerich]
Yes. Well, by the way, no, I have to correct myself, 11there is no -- we do not have a written, a written 12statement by Hitler signed by Hitler, you know, that the 13Jews have to be killed. This is something we do not have. 14Q.
[Mr Irving]
On page 55 of your report, 15.1, you begin by saying: "In 15the course of the preparations for the racist war of 16extermination against the Soviet Union", that is rather 17colourful language, is it not? 18A.
[Dr Heinz Peter Longerich]
Well, this is actually a language which is commonly used 19by historians to describe the specific nature of this war. 20Q.
[Mr Irving]
Yes. It is not really material here except that it goes 21to your state of mind, I suppose, but are you not aware 22that there is a body of historical opinion on the other 23side now which says that to a certain extent, 24notwithstanding that Hitler had always wanted to fight the 25Soviet Union, by June 1941 it also had a preventive 26character?

. P-115

1A.
[Dr Heinz Peter Longerich]
No, I do not accept this thesis. I think it does not 2convince me at all. These historians have not produced, 3in my opinion, enough evidence to prove that Hitler was 4just, well, fighting a preventive war. 5Q.
[Mr Irving]
Preventive war? 6A.
[Dr Heinz Peter Longerich]
Yes. 7Q.
[Mr Irving]
I did not say he was just fighting a preventive war 8because I said that there was certainly evidence that he 9had always wanted to fight the Soviet Union. I chapter 14 10of Mein Kampf goes that way, does it not? But Stalin's 11biographer, General Volkagonov, has presented documents 12from Stalin's own private archives indicating that the 13Russians were planning to attack Germany? 14A.
[Dr Heinz Peter Longerich]
I do not think there is enough evidence now. I mean, 15I know that research is going on, and one actually can 16find more material in Soviet archives, but at the moment 17I do not think that the case is made that Hitler was just 18fighting a preventive war against the Soviet Union and 19that Stalin had decided to attack Hitler somewhere in the 20summer 1941. 21Q.
[Mr Irving]
Once again, I did not say he was just fighting a 22preventive war, but it had a preventive element? 23A.
[Dr Heinz Peter Longerich]
I do not accept this. I think, from the German side, if 24you follow the preparations, I mean, I am, of course, more 25an expert -- expert on the Germans, not on the Soviets. 26I am just following the discussion, but on the German

. P-116

1side, it is quite clear in the preparations, from my point 2of view, that Hitler actually is planning this war since 3the summer of 1940, and in the documentation that there is 4actually, as far as I am aware, almost no reference to the 5policy of behaviour of the other side. So I think it is 6the main reason for this was really, on the one hand, the 7ideological belief of Hitler that he has to destroy this 8so-called Bolshevik Empire and, on the other hand, he is 9trying to find a way out of the general, the war situation 10he found himself in in the summer of 1940 when Britain was 11not prepared to surrender. So I do not share this view, 12that it was to some extent a preventive war. 13Q.
[Mr Irving]
Or to any extent at all a preventive war? 14A.
[Dr Heinz Peter Longerich]
No, I do not share this view. 15Q.
[Mr Irving]
I do not want to labour the point, but I am just drawing 16attention to the fact that in that first line you do 17appear to throw around words like "extermination" rather 18loosely. 19A.
[Dr Heinz Peter Longerich]
I do not think I throw around; I just say that, in my 20opinion, if you follow this documentation, I think it is 21fair to say that this was a racist war of extermination 22from, you know, as both, if you look at the preparation 23and planning and, on the other hand, if you then look at 24what happened after the 22nd June 1941. 25Q.
[Mr Irving]
We are looking now at Hitler's instructions to the High 26Command Operations staff, March 3rd 1941. These are the

. P-117

1guidelines which I believe I gave your Lordship in 2complete translation a few days ago, the English 3translation of the document. 4MR JUSTICE GRAY: Yes, I think you did. 5MR IRVING: Is there any indication in that document, apart 6from that quoted paragraph, that there is an intention 7when the Russian campaign begins to liquidate the Jews as 8such rather than just the leadership? 9A.
[Dr Heinz Peter Longerich]
I do not have the full document in front of me, so 10I cannot answer this, but you could probably help me. 11Q.
[Mr Irving]
But you would have quoted it if it was in the document? 12A.
[Dr Heinz Peter Longerich]
I think I looked through the document and if I did make a 13mistake, it is nothing, there is not such a phrase in 14document. 15Q.
[Mr Irving]
I think we can take it that Hitler himself is the author 16of this document, can we? 17A.
[Dr Heinz Peter Longerich]
Yes. 18Q.
[Mr Irving]
When Hitler refers to the Jewish Bolshevik intelligentsia, 19der Judisch Bolschewikisch intelligentsia, he is referring 20to the people around Stalin and the leadership of the NKBD 21and the Commissarts, that kind of people? 22A.
[Dr Heinz Peter Longerich]
Well, I think the top leadership but also the Party 23functioners, I think. 24Q.
[Mr Irving]
Whether they were Jewish or not, he just put them all into 25one package? 26A.
[Dr Heinz Peter Longerich]
The Jewish Bolshevik intelligence, yes, Jews and non-Jews

. P-118

1probably. 2Q.
[Mr Irving]
This was part of the Nazi party jargon, was it not? It 3was part and parcel -- it was a word they liked using a 4lot? 5A.
[Dr Heinz Peter Longerich]
Yes, but it refers to the fact that they were convinced 6that Bolshevism or Marxism is a kind of sinister, you 7know, tool of the Jews, you know, in order to destroy the 8Aryan people. This is, I think, the background. It is 9just not, it is just not kind of jargon. It has a thing, 10it has a background. 11Q.
[Mr Irving]
The further quotations that you put on that page from the 12papers of General Thomas ---- 13A.
[Dr Heinz Peter Longerich]
Yes. 14Q.
[Mr Irving]
--- who I incidentally learned was the father-in-law of my 15private secretary after 20 years she worked for me, oddly 16enough. It is a small world. These are just references 17to destroying the Soviet leadership? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
Or murdering them or killing them? 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Irving]
Would that be a legitimate military aim to discuss with 22the German High Command? 23A.
[Dr Heinz Peter Longerich]
Well, it gives you a kind of insight about the nature of 24this war because they are not planning only to annihilate 25or exterminate the Russian Army, but also they are trying 26to crush the whole system, including killing, obviously,

. P-119

1the leadership. So it is far more than a normal war when 2two armies fight against each other, and, yes, and ---- 3Q.
[Mr Irving]
So it is just one step up the ladder, shall we say, of 4extermination? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
So it is not the whole way, but it is an interesting rung 7in the ladder? 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Irving]
If we can put it like that? Turning to page 56, please, 10paragraph 15.4, you refer to Hitler's guidelines of 3rd 11October? 12A.
[Dr Heinz Peter Longerich]
Yes. It is a mistake. 3rd March. Sorry about that. 13Q.
[Mr Irving]
3rd March. 14A.
[Dr Heinz Peter Longerich]
15.4, first line, should have "March" instead of 15"October". 16Q.
[Mr Irving]
In this directive it says, this is the directive of March 1713th issued by General Alfred Jodl: "In the operation 18area of the Arm, Himmler is granted special 19responsibilities by order of Hitler for the preparation of 20the political administration." 21A.
[Dr Heinz Peter Longerich]
Yes, but it is also -- yes, sorry. 22Q.
[Mr Irving]
It looks pretty sinister and it probably is pretty 23sinister, but is this not within the guidelines of 24military operations, securing the rear areas? 25A.
[Dr Heinz Peter Longerich]
Yes, but it says if you take the full, if you look at the 26German terminology, "die sich aus dem endgultig

. P-120

1auszutragenden Kampf zweier entgegengesetzter politischer 2Systeme ergeben", this is in English "These special 3responsibilities arise from the ultimate decisive struggle 4between two opposing political systems". So it is not 5about just two armies fighting against each other. It is 6actually two political systems and the idea here is to 7completely, well ---- 8Q.
[Mr Irving]
National socialism, on the one hand, and Bolshevism on the 9other? 10A.
[Dr Heinz Peter Longerich]
Yes. 11Q.
[Mr Irving]
I think somebody once said the child with most -isms is 12the -ists. So they are dealing here with the Bolsheviks 13or the Bolshevists and the National Socialists rather than 14the Jews as such? 15A.
[Dr Heinz Peter Longerich]
Well, but from the context it becomes quite clear that in 16the views of the National Socialist, you cannot separate 17Bolshevism from Jewry, so it is a kind of, it is quite 18clear it is one of the main elements of the National 19Socialist ideology that Bolshevism is in a way a kind of 20invention of the Jews, of all Jewry, in order to conquer 21world dominion, I think. This is something that you 22cannot separate here from this. 23Q.
[Mr Irving]
Sure enough in the next paragraph it spells out what the 24special responsibilities are. They are going to be 25bumping of all the Bolshevik Chieftains and Commissarts? 26A.
[Dr Heinz Peter Longerich]
Yes.

. P-121

1Q.
[Mr Irving]
I agree with that. That is quite obviously contained in 2the documents. We now go on the following page to page 57 3to the massacres executed by the four Einsatzgruppen? 4A.
[Dr Heinz Peter Longerich]
Yes. 5MR JUSTICE GRAY: But can I just be clear about that? Forgive 6me. The documents we have just been looking at, four of 7them, 3rd March onwards? 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Justice Gray]
Do you regard those as being preliminary to the setting up 10of the Einsatzgruppen? 11A.
[Dr Heinz Peter Longerich]
Yes, I think one has to bear in mind that this is, you 12know, this is preparation of a racist war of 13extermination. So the result of the speeches and of these 14instructions are certain guidelines which are given to the 15troops. This is the Commissart order, the order to kill 16all Communist Commissarts, and this is what was called 17here the guidelines for special areas. And then there is 18the jurisdiction decree which says, basically, that every 19German officer is entitled to take retaliation measures on 20the spot, and they are the guidelines for the conduct of 21the troops in Russia. 22 So the whole of it has to be seen as a whole set 23of regulations and guidelines, which I think can be 24described as a kind of package for the racist war of 25extermination and Hitler is intimately involved in the 26preparation of this.

. P-122

1MR IRVING: As a what for the racist war? 2MR JUSTICE GRAY: "Package". 3A.
[Dr Heinz Peter Longerich]
A kind of package of set of documents which actually ---- 4MR IRVING: You describe them as the prerequisites ---- 5A.
[Dr Heinz Peter Longerich]
Yes, exactly. 6Q.
[Mr Irving]
--- which does not necessarily mean that the one flowed 7from the other. The racist war of extermination would not 8have been possible without these prerequisites, but that 9does not necessarily mean that this was anticipated or 10planned? 11A.
[Dr Heinz Peter Longerich]
Well, I think it is quite clear from the documents that 12this war, you know, this racist war, is planned from at 13least March 1941 onwards and Hitler is playing an active 14role in the preparations of those guidelines. 15Q.
[Mr Irving]
Dr Longerich, if you are going to put it like that, I 16think you ought to point us to the passage of the March 17documents on which you are relying. 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
Am I right, my Lord, that he should ---- 20MR JUSTICE GRAY: Yes, you are, but I do not want to assume too 21much, but 3rd March refers to the establishment of 22guidelines? 23A.
[Dr Heinz Peter Longerich]
Yes, it is an instruction from Hitler to Jodl to actually 24rephrase the guidelines, to be more radical in those 25guidelines. So it gives him a kind of idea of what he 26wants, and he says, this is the key sentence, "The Jewish

. P-123

1Bolshevik intelligentsia must be eliminated". Then they 2are going on and revising these guidelines, and in end it 3says in here that there is in the operational area of the 4Army, the Reichsfuhrer SS special duties, he has to carry 5out and these duties relates to the fight between 6Bolshevism and National socialism. 7 So there is a specific political racist, I would 8say, element in here. It is not just a preparation of, 9let us say, a normal war between nations or armies. 10MR IRVING: Racist or ideological? 11A.
[Dr Heinz Peter Longerich]
Both. You cannot separate that. You cannot separate 12anti-Semitism from the anti-Communism. This is one thing. 13Q.
[Mr Irving]
But if I narrow it down, these actual documents before us 14refer only to the leadership, the intelligentsia. 15Everything beyond that is extrapolation by yourself, is it 16not? 17A.
[Dr Heinz Peter Longerich]
I do not know what the "Sonderaufgaben im Auftrage des 18Fuhrers" are. There is no -- the document does not give 19us any explanation for that. It is not -- the documents 20refer to leaders and to special tasks "im Auftrage des 21Fuhrers", "on behalf of the Fuhrer", so I do not know what 22this actually, I mean, because I was not there and we do 23not have a document about this, I do not know what this 24means. 25Q.
[Mr Irving]
This is the document of March 13th on page 56, is that 26right?

. P-124

1A.
[Dr Heinz Peter Longerich]
Yes. "Sonderaufgaben", special tasks on behalf of the, by 2order of the Fuhrer for the preparation, and so on, and so 3I do not know what this really, how far ---- 4Q.
[Mr Irving]
Is it likely that Himmler went to see Hitler a bit jealous 5because the Army and the Air Force and the Navy had been 6given all these great tasks for this great ideological 7campaign in the East and Himmler has been to see Hitler 8and said, "Mein Fuhrer, I want jobs too. What are you 9going to give me?" and Hitler says to him, "Well, you are 10going to do this and you are going to do that. Your job 11is in the rear area, mopping up the partisans, holding 12down the population, securing the transport routes"? 13A.
[Dr Heinz Peter Longerich]
No. What happens is that I think the initiative came from 14Hitler because he is the one who is revising, first of 15all, the instruction, the guidelines by giving Jodl this 16instruction. So he is the one who thinks that the Army is 17not radical enough about, the Army has not completely 18understood the task ahead of them. 19Q.
[Mr Irving]
The ideological nature? 20A.
[Dr Heinz Peter Longerich]
The ideological was, so he is giving this instruction. 21Then in the end it is ended in these guidelines where 22these special tasks are mentioned. 23Q.
[Mr Irving]
Dr Longerich, you are interested in the special tasks, are 24you not? We do not know what they are, but can I remind 25you of the meeting after Barbarossa began on July 16th 261941 where Himmler is given special tasks, is he not?

. P-125

1A.
[Dr Heinz Peter Longerich]
Well, he is then -- what he gets then is special tasks. 2He gets ---- 3Q.
[Mr Irving]
Pacifying the rear areas? 4A.
[Dr Heinz Peter Longerich]
Yes, he wanted more. He wanted the overall political -- 5he wanted a political -- he wanted the responsibility, the 6political responsibility, in a way to reorder the whole 7area. What he got there on 16th is the competence for the 8political -- for the security -- for securing. 9Q.
[Mr Irving]
Securing the rear area? 10A.
[Dr Heinz Peter Longerich]
Securing the rear area. So it is the word "police" is the 11crucial word in this. 12Q.
[Mr Irving]
"Police"? 13A.
[Dr Heinz Peter Longerich]
"Police". 14Q.
[Mr Irving]
So did Hitler on that 16th July 1941 meeting effectively 15give Himmler carte blanche? I am anxious not to lead you 16in any way on this. If you disagree, then please say so. 17A.
[Dr Heinz Peter Longerich]
Yes, I think the meeting is decisive and we can see after 18the meeting that actually Himmler sent more men to the 19East and the killings were radicalized and, you know, and 20the whole process escalated. 21Q.
[Mr Irving]
And is it possible (and I put this as a hypothesis to you 22and it may militate against me or for me, I do not know) 23that Hitler may have said to Himmler, "Herr Reichsfuhrer, 24do what you see best, do whatever you think is right, but 25do not tell me what you are doing"? Would that be 26possible? "Just keep me out of it"?

. P-126

1A.
[Dr Heinz Peter Longerich]
It is difficult for me to speculate about this. 2Q.
[Mr Irving]
On the basis of their relationship, as we know? 3A.
[Dr Heinz Peter Longerich]
It is really difficult for me to speculate about this 4question, what he actually said, because I do not have 5minutes or anything about that. I find it difficult 6to answer this question. 7Q.
[Mr Irving]
But later on we do find in 1942 the documents where 8Himmler says: "The Fuhrer has ordered the Eastern 9territories to be rid of the Jews. He has placed this 10burden on my shoulders. Nobody can take it off me"? 11A.
[Dr Heinz Peter Longerich]
Yes. 12Q.
[Mr Irving]
And that rather fits in with that kind of hypothesis? 13I only want to put it you if you think you are comfortable 14with it. 15A.
[Dr Heinz Peter Longerich]
I find this difficult to answer. You can, of course, 16argue that, in general, how this system, the political 17system, worked, the decision-making worked, that Hitler 18would make a general statement, gave general guidelines, 19and then leave it to other people responsible for this 20area actually to fill this out, you know, with their own 21energy and their own ideas, but really I do not know about 22the exact content of this guidelines. 23Q.
[Mr Irving]
If it repeatedly happened that somebody like Hans Lammers 24went to see Hitler to protest about this or that, and 25Hitler would answer, or Ribbentrop would go to Hitler, and 26Hitler would answer, "Keep me out of this. Take it up

. P-127

1with Himmler. It is his pigeon, it is his business"? 2A.
[Dr Heinz Peter Longerich]
Well, I think, if we want to, if we want to discuss it, 3I think we have to discuss these individual letters or 4pieces of documents. 5Q.
[Mr Irving]
It is just a general impression I was asking you about 6from your knowledge of the papers. So what we differ on, 7Dr Longerich, is this, am I right in saying this, that the 8March 1941 documents, you think it was an ideological 9preparation for the ideological war in the East, that 10Himmler was being given orders for, and I say it was a 11typically military securing the rear areas kind of job he 12was being given? 13A.
[Dr Heinz Peter Longerich]
Well, you cannot separate the Nazi ideas of warfare in the 14East from their ideological goals. I mean, for them it 15was not contradiction to speak about securing of areas and 16to speak of ideological goals. I do not think one can 17separate these two issues. 18MR JUSTICE GRAY: Can I just ask you this, Dr Longerich. Do 19you regard it as legitimate in deciding what the objective 20was to look and see what actually happened? 21A.
[Dr Heinz Peter Longerich]
Yes, of course. 22Q.
[Mr Justice Gray]
Because we know pretty precisely what happened? 23A.
[Dr Heinz Peter Longerich]
Yes, of course. 24MR IRVING: I will come to that question as question B, but, 25first of all, I will ask question A, if I may, my Lord? 26Would you agree that the documents before us fit entirely

. P-128

1with the notion of military securing of rear areas? 2A.
[Dr Heinz Peter Longerich]
No, because it says, if you just look at the documents and 3leave out what happened after that, it says here: 4"Special responsibilities by order of the Fuhrer for the 5preparation of the political administration. These 6special responsibilities arise from the ultimate decisive 7struggle between two opposing political systems". So it 8is not just about policing and security. 9Q.
[Mr Irving]
Would that include the murder and extermination of the 10political and military leaders on the other side, the 11intelligentsia? 12A.
[Dr Heinz Peter Longerich]
Yes, I think so. 13Q.
[Mr Irving]
Now, if we turn the page and now we come to the four 14Einsatzgruppen, page 57? 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
I am only going to ask you one question about this because 17I think we accept what happened there, that killings 18began, but this is going to be now questions B to start 19with, the fact that the killings began, is there any 20indication that they began as a direct result of these 21orders and guidelines or did they just begin of their own 22accord like a spontaneous combustion? 23A.
[Dr Heinz Peter Longerich]
No. We have, I think, quite good documentation because we 24have Heydrich's order of 29th and Heydrich's letter to the 25highest SS police leader of ---- 26Q.
[Mr Irving]
I think the 2nd July.

. P-129

1A.
[Dr Heinz Peter Longerich]
--- 2nd July which actually gives you a very clear idea 2what the task of the Einsatzgruppen was. 3Q.
[Mr Irving]
The 2nd July one which, my Lord, I am afraid I still have 4not translated for your Lordship -- we are working on it 5-- this is 2nd July 1941 where Heydrich, am I correct, 6says to the people in the Baltic states: "If pogrom 7start, you are not to stop them and, in fact, you are to 8help them along"? 9A.
[Dr Heinz Peter Longerich]
Yes. I ---- 10Q.
[Mr Irving]
"But don't let it be seen"? 11A.
[Dr Heinz Peter Longerich]
I think I translated this in the second part of my 12report. This is at page 6, and if you look at the English 13translation, I have to say here that I have, 14unfortunately, made a mistake here which I have to correct 15because if you read this indented paragraph "To be 16executed are", you have to add the word "or" to the first 17line, "To be executed are all" and then it goes on 18"functionaries of the Comintern", and so on, so that the 19word "all" ---- 20MR JUSTICE GRAY: So all of the lot of them? 21A.
[Dr Heinz Peter Longerich]
"All" also relates to the last line, "All Jews in Party 22and State functions", so this is the way the original 23German document is arranged. So we know from this 24document that Heydrich ordered the Einsatzgruppen to 25execute all Jews and part -- all Jews in Party and State 26functions and the more, I think most interesting word in

. P-130

1this "all" is the next line which you find on page 7 and 2"other, and all other radical elements including", the 3most important word is I think the "etc." in the end, 4which says, "Well, this is not a definite list of the 5people we are going to kill". You know, you actually, you 6know, can add to the list. You can add saboteurs, 7propagandists, snipers, assassins and agitators, others 8who fall into this category. 9MR IRVING: But am I right in saying ---- 10A.
[Dr Heinz Peter Longerich]
My interpretation of this order is that this is a kind of 11open, very general order which appeals to the initiative 12of the men in the field. They can actually go and extend 13the killings if they find it appropriate, if it is 14feasible. 15Q.
[Mr Irving]
An umbrella order? 16A.
[Dr Heinz Peter Longerich]
Sorry? 17Q.
[Mr Irving]
It is a kind of umbrella order? 18A.
[Dr Heinz Peter Longerich]
Yes. Also, there is no indication in this order who 19actually is to be spared. It does not say, for instance, 20it is not allowed to shoot women. 21Q.
[Mr Irving]
Why should it not be allowed to shoot women? 22A.
[Dr Heinz Peter Longerich]
Well, it is not said in this order here. 23Q.
[Mr Irving]
If there is a woman kommissar she was going to be spared, 24or a woman sniper? 25A.
[Dr Heinz Peter Longerich]
Then would assume that this is a Jew in party or state 26function, or it is one of the propagandists, saboteurs

. P-131

1snipers, and so on. So I think this is not ---- 2Q.
[Mr Irving]
Dr Longerich, I really want to come to this July 2nd 3document tomorrow when we deal with your second report, 4but I do draw attention to your footnote there, the second 5line from the bottom, the only Jews who are actually 6included in that are the Jews in party and state positions 7who are on the shooting list. 8A.
[Dr Heinz Peter Longerich]
Yes, and the word "etc." in the end, I think in my 9interpretation ---- 10Q.
[Mr Irving]
That could mean anything. It could mean the milkmen and 11everybody else, could it not? 12A.
[Dr Heinz Peter Longerich]
Yes, everybody else, everybody Jew or non-Jew who was 13suspicious from the point of view of the Nazis, the 14invaders. 15Q.
[Mr Irving]
Can I now take you back to page 57, where we are looking 16at the Einsatzgruppen? 17A.
[Dr Heinz Peter Longerich]
Yes. 18Q.
[Mr Irving]
I take it from your footnote that you have not made any 19use of the police decodes that are in the Public Record 20Office? 21A.
[Dr Heinz Peter Longerich]
I have looked at the police decodes, both in the 22collection here and also at the collection in Washington. 23I have seen several hundred of them, not more. 24Q.
[Mr Irving]
Since you wrote this report or before that? 25A.
[Dr Heinz Peter Longerich]
I saw the Washington decodes about two years ago and the 26ones here after I finished the report, I think.

. P-132

1Q.
[Mr Irving]
Just a subsidiary question: How would you rate the 2decodes as a source? Are they really pure gold, untouched 3and unimpeachable integrity as a source? 4A.
[Dr Heinz Peter Longerich]
In the sense that they are authentic? 5Q.
[Mr Irving]
Authentic and likely to contain something approximating to 6the truth? 7A.
[Dr Heinz Peter Longerich]
We have actually the chance in some cases to complete the 8deciphers with the German originals in this case. 9Q.
[Mr Irving]
Compare them? 10A.
[Dr Heinz Peter Longerich]
Sorry, compare them, and in this case it is clear that 11they are authentic. The problem with the deciphers is 12that they are relating to the order police, which is one 13branch of the German police. A second problem is that the 14German would use, as far as I am aware, a different code 15for the highest class of classified documents. They would 16not use this code. The Einsatzgruppen would not send 17their messages through the order police system. It is 18clear from one of the deciphers from September that the 19Germans were aware of the danger that the codes could be 20broken and the Deluger sent an order to say what actually 21---- 22Q.
[Mr Irving]
Keep the figures up or something? 23A.
[Dr Heinz Peter Longerich]
Be quite cautious here what you are sending. Also, we do 24not know how comprehensive actually the work of the 25deciphers were. Is this everything they got? Is this the 26whole communication of the German police? So I think we

. P-133

1will spend, as historians always spend, a lot of time 2actually to assessing this document and to find out to 3which extent it will help us to understand the killings 4better than we did before. 5Q.
[Mr Irving]
I have to take up two points. First of all, you say that 6because it is the Ordnungs Polizei, the order police, it 7does not contain a high level of material, but we have 8seen in this courtroom messages from Himmler to Jeckeln, 9and that is of course at the very highest level, is it 10not? 11A.
[Dr Heinz Peter Longerich]
The high SS police leader would use the communication 12system of the order police. That is possible, yes. 13Q.
[Mr Irving]
Would you accept, having spent some time looking at these 14decodes, that they are a pretty random selection, that 15they are not methodologically skewed in any way? Although 16it is not 100 per cent, the volume of documents that has 17been left for us to look at is a random collection of many 18hundreds of thousands of items? 19A.
[Dr Heinz Peter Longerich]
I am not sure what the numbers -- what I am trying to say 20is, if you look at the deciphers, you cannot be sure that 21the deciphers contain the whole radio communication 22between, let us say, Himmler and Jeckeln, for instance. 23I have no way to find out how comprehensive and how 24representative this collection is. But of course it adds 25to our knowledge. 26Q.
[Mr Irving]
Yes. You did not have those, just to make this quite

. P-134

1plain, at your disposal when you wrote this report? 2A.
[Dr Heinz Peter Longerich]
I looked into some of the Washington files. 3Q.
[Mr Irving]
The Washington files are not as complete as the British 4files? 5A.
[Dr Heinz Peter Longerich]
Yes, exactly. 6Q.
[Mr Irving]
Yes. 7A.
[Dr Heinz Peter Longerich]
I had the Washington files in front of me when I wrote the 8report, and I did not include them here because what I 9have seen in Washington for me -- for instance, I did not 10find in Washington the Himmler Jeckeln correspondence and 11I did not spend enough time probably on it, but there is 12nothing in it which actually I thought was valuable enough 13to include it into the report. 14MR JUSTICE GRAY: Mr Irving, could you put, really for my 15benefit as much as anybody else's, to Dr Longerich what it 16is you say about the decodes that is significant. 17MR IRVING: I am just about to come to that very point, my 18Lord. 19MR JUSTICE GRAY: Good. 20MR IRVING: You say you were not at that time familiar with the 21Himmler and Jeckeln decodes? 22A.
[Dr Heinz Peter Longerich]
Yes. 23Q.
[Mr Irving]
Have you in the meantime had a chance to look at them? 24A.
[Dr Heinz Peter Longerich]
Yes. 25Q.
[Mr Irving]
I am referring here to the decodes of November 30th, the 26telephone call from Himmler to Heydrich on November 30th,

. P-135

1and principally I am going to ask you now about the deeds 2codes of December 1st 1941. 3A.
[Dr Heinz Peter Longerich]
Yes. 4Q.
[Mr Irving]
There are three? 5A.
[Dr Heinz Peter Longerich]
Yes. 6Q.
[Mr Irving]
The first one is a message from Jeckeln to Himmler on the 7morning. My Lord, do you want to have the items in front 8of you? 9MR JUSTICE GRAY: I am trying to follow but the documents are 10now even more scattered about. 11MR RAMPTON: No, they are not. 12MR IRVING: They should now be ---- 13MR RAMPTON: They are now collected in here. 14MR JUSTICE GRAY: I know, but I had marked the previous 15versions of them, that is the problem, and these are all 16in German. 17MR RAMPTON: No, they are not. 18MR IRVING: I have translated them. 19MR RAMPTON: Wherever possible the English has been put 20opposite the German. 21MR JUSTICE GRAY: 31st December? 22MR IRVING: 1st December, my Lord. 23A.
[Dr Heinz Peter Longerich]
Page 142, if I am right on this, in this blue bundle. 24MR JUSTICE GRAY: Thank you very much. 25MR IRVING: There should be three altogether. The first one is 26page 141. This is 9.15 in the morning. This is from the

. P-136

1senior SS police commander, north Russia, to Berlin, 2saying: "I need by next available air courier 10 Finnish 3military pistols with two drum magazines, each execution 4of Sonderaktionen". He requests a radio telegram reply. 5What inference do you draw from that? 6A.
[Dr Heinz Peter Longerich]
I do not know whether the term Sonderaktionen refers here 7to shootings, and I do not know whether these Finnish 8pistols were used. 9Q.
[Mr Irving]
Is it a reasonable inference if I say that this is 10probably a reference to the machine gunning of Jews into 11pits? 12A.
[Dr Heinz Peter Longerich]
I do not know. It says militairpistol. This is not a 13machine gun or short machine gun. 14Q.
[Mr Irving]
Execution of Sonderaktionen? 15A.
[Dr Heinz Peter Longerich]
I am not sure. I think it is reasonable to argue this 16line, but I do not know whether ever Finnish military 17pistols were used. They had their own weapons. I do not 18see a reason why they urgently needed for these executions 19Finnish weapons. It does not make sense for me. It might 20be right, but I do not know the background. 21Q.
[Mr Irving]
Might not there be reasons of camouflage? They wanted, if 22bodies were dug out, to have Finnish bullets found in the 23bodies rather than German bullets? This kind of thing 24might have been in it. 25A.
[Dr Heinz Peter Longerich]
We have enough expertise information that they use 26normally the standard Army pistol.

. P-137

1Q.
[Mr Irving]
Tommy gun? 2A.
[Dr Heinz Peter Longerich]
The 9 millimetre pistol for these operations. Actually 3I have not found something like that. 4Q.
[Mr Irving]
Dr Longerich, the ones I really rely on are page 143, two 5messages that afternoon, or evening rather, 7.30 p.m., 6both at the same time. One from Himmler's adjutant, 7Grotmann, and one from Himmler himself, to Jeckeln. 8Jeckeln was the chief villain, was he not? He was one of 9the biggest murderers in Riga. 10A.
[Dr Heinz Peter Longerich]
Yes he was the highest SS police leader. 11Q.
[Mr Irving]
The chief SS police leader. The first one summons him to 12a conference with Himmler on 4th December? 13A.
[Dr Heinz Peter Longerich]
Yes. 14Q.
[Mr Irving]
The second one, even more peremptorily, from Himmler 15himself says to him, "The Jews being outplaced to the 16Ostland are to be dealt with only in accordance with the 17guidelines laid down by myself and/or by the 18Reichssicherheitshauptamt on my orders. I would punish 19arbitrary and disobedient acts". 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Irving]
That looks like quite an important telegram or message? 22A.
[Dr Heinz Peter Longerich]
I think you will relate this to the telephone call of 13th 23November, and I think you are right to do so. 24Q.
[Mr Irving]
I am anxious to hear your opinion about it because it 25appears to be significant. 26A.
[Dr Heinz Peter Longerich]
Yes. I think these are two significant and important

. P-138

1entries. 2Q.
[Mr Irving]
Yes. Let me float a hypothesis past you, Dr Longerich. 3Does this indicate to you that Jeckeln has acted outside 4the authority that he believed he had to kill Jews? 5A.
[Dr Heinz Peter Longerich]
I think this is a fair assumption. I think this is 6absolutely possible. Also, I find it quite striking, if 7this is right, if Jeckeln is actually responsible for the 8murder of 6,000 people, what is the consequence of that? 9Is he then court martialled? Or he is thrown out of the 10SS? No. He got a nasty letter. 11Q.
[Mr Irving]
A rap across the knuckles? 12A.
[Dr Heinz Peter Longerich]
Yes. That is all he got. Then he had dinner with Himmler 13on the 4th and that is it, obviously. It was probably a 14violation of the guidelines but it was not seen as a kind 15of severe disobedience, a lapse or something like that. 16Q.
[Mr Irving]
These were just Jews, were they not? They were German 17Jews but just Jews? 18A.
[Dr Heinz Peter Longerich]
That is probably true, yes. That is definitely true. 19Q.
[Mr Irving]
I think no one disputes the fact that this is a gangster 20state and these are gangsters amongst themselves are they 21not? 22A.
[Dr Heinz Peter Longerich]
Yes. 23Q.
[Mr Irving]
Did the killings then stop for a while as far as German 24Jews were concerned? 25A.
[Dr Heinz Peter Longerich]
As far as we know, the killing on a large scale, mass 26executions, stopped in Riga until a couple of months,

. P-139

1until they used gas vans at the beginning of 1942. 2MR JUSTICE GRAY: Just in Riga or elsewhere as well? 3A.
[Dr Heinz Peter Longerich]
Well, to make this quite clear, there were two waves of 4deportation, the first one to Lodz of 20,000 Jews in 5October, and the second one, they planned to deport 50,000 6people, 25,000 each to Riga and to Minsk. They managed to 7deport about 21,000 to Riga or 24,000, and 8,000 to 8Minsk. The general observation is that it was obviously, 9as far as I see it, not the policy to kill them all 10because we do not have mass executions at this time in 11Lodz concerning German Jews and in Riga concerning German 12Jews. We only have these six trains in Kovno and Riga, 13and this was stopped. It was obviously, as is said here, 14not in accordance with the guidelines given by the 15Reichssichherheitshauptamt . 16MR IRVING: It is a strange little glimpse of history which you 17have come across now at the end of the 20th century, 55 18years or more after the events. Is this an indication to 19you of how history is constantly in flux? 20A.
[Dr Heinz Peter Longerich]
No. These two messages confirm what we actually knew 21before. Obviously these killings in Riga were obviously 22not in accordance with the guidelines of the 23Reichssicherheitshauptamt and now we have another 24confirmation by these two telegrams. 25Q.
[Mr Irving]
Has it been very widely noised around among German 26historians that the orders came down from on high that

. P-140

1these killings had to stop? I have never heard it 2before. 3MR RAMPTON: That is a slightly tricky way of putting that 4question. What does Mr Irving mean by on high? 5MR JUSTICE GRAY: I think that is right. The problem is -- 6I think this is what Mr Rampton is really saying -- that 7there are guidelines. We do not know quite what the 8guidelines say. That is the difficulty. We cannot assume 9that the guidelines say no killing, full stop. 10MR IRVING: I was tempted to say from the Fuhrer's 11headquarters, but then Mr Rampton would certainly have 12objected. 13MR JUSTICE GRAY: That is a separate point. 14MR RAMPTON: No. Himmler was probably somewhere in that 15complex at the Wolfsschanze when the telephone call of 1630th November was made. That is as far as one can push at 17what one might call wishful thinking. 18MR JUSTICE GRAY: Can I just ask the question? There obviously 19were guidelines knocking around somewhere? 20A.
[Dr Heinz Peter Longerich]
Yes. 21Q.
[Mr Justice Gray]
Do you take the view that the guidelines said no Jews, 22German Jews or any other Jews, to be killed ever? 23A.
[Dr Heinz Peter Longerich]
No. 24Q.
[Mr Justice Gray]
Or what? 25A.
[Dr Heinz Peter Longerich]
I have not seen these guidelines. 26Q.
[Mr Justice Gray]
No. Nobody has.

. P-141

1A.
[Dr Heinz Peter Longerich]
I think I should not speculate on the guidelines. As far 2as I see this, the Holocaust emerged in different phases. 3We have the Soviet Jews who were killed during the summer 4first, and then the killing was extended in the autumn of 541 to parts of Poland and to Serbia, then in the spring 6and summer of 42 to other areas. So the German Jews at 7this stage were deported into these ghettoes, and the 8majority of them survived until the spring of 1941. So it 9was not policy at this moment, I think, as far as I know, 10as far as I am able to reconstruct this, to kill 11systematically German Jews on arrival in the ghettoes in 12Minsk, Riga and Lodz. Here obviously Jeckeln, let me put 13it this way, made a mistake, which is quite difficult to 14say because it involved the death of 6,000 people. But it 15was obviously not the policy of the 16Reichssicherheitshauptamt to kill every German Jew who was 17deported in the East at this stage. 18MR JUSTICE GRAY: Was it the policy to kill some of them in so 19far as you can speculate? 20A.
[Dr Heinz Peter Longerich]
When this happened, as I said, there was no severe 21punishment for that. It was not seen as a major 22violation. It was seen as a minor incident. 23MR IRVING: That is a different matter, whether it was 24punishable or not. Can I ask you to look back at page 122 25of that bundle of German documents, the same one? It is 26another decode.

. P-142

1A.
[Dr Heinz Peter Longerich]
Yes. 2Q.
[Mr Irving]
Now this one you may also have seen in view of the fact 3that I found it in the PRO and brought it to the attention 4of the court. It concerns the shipment of train loads of 5Jews. 6A.
[Dr Heinz Peter Longerich]
Where are we? 7Q.
[Mr Irving]
Page 122 of the bundle of documents. It concerns whether 8there was a homicidal intention already in store for the 9train loads of Jews being sent out of Germany. This is a 10train load of Jews. It is a telegram. I will ask you 11just to read it first and then I will ask you some 12questions. 13A.
[Dr Heinz Peter Longerich]
This is the first train to Kovno. The people were all 14killed in Kovno. 15Q.
[Mr Irving]
Thank you for telling us. That is very interesting to 16know that. This is the train load on November 17th 1941, 176.25 p.m., the transport train number DO, presumably that 18is Deutschland Ost, 26th, has left Berlin for Kovno with 19944 Jews on board, details of what the transport escort 20is. Then it says the transport has been provided with 213,000 kilograms of bread, 27 hundred kilograms of flour, 22and various other things, which indicates that they were 23going to have enough food for the journey and some. 24A.
[Dr Heinz Peter Longerich]
Yes. 25Q.
[Mr Irving]
There is another telegram, I am not sure if it is in this 26bundle or not, Miss Rogers will know, which actually says

. P-143

1they are going to be taking their Gerat with them. 2A.
[Dr Heinz Peter Longerich]
Tools. 3Q.
[Mr Irving]
Their tools or appliances? 4A.
[Dr Heinz Peter Longerich]
Yes. 5Q.
[Mr Irving]
Does that imply they anticipated the people sending them, 6anticipated they were going to be going to a new life, if 7I can put it that way? 8MR JUSTICE GRAY: We had this this morning, you got the answer 9you wanted. They were lured into thinking that they were 10going to a new life in the East. 11MR IRVING: Very well, but am I right now, Dr Longerich, you 12said that this particular train load, which was referred 13to here, which I did not know, I have to confess, ended up 14being murdered? 15A.
[Dr Heinz Peter Longerich]
The first five trains to Riga were diverted to Kovno and 16these are the trains where the people were killed, and the 17first train to Riga as well. If I am not completely 18mistaken, I am pretty sure the people on this train were 19killed. 20Q.
[Mr Irving]
So would this indicate a totally chaotic situation? The 21people in Germany who were sending them out, assume they 22are going to need tools and bread for a new life, whereas 23the people who received them, bumped them off as they 24arrived? 25A.
[Dr Heinz Peter Longerich]
Again, the tools and the food was provided by the Jewish 26community.

. P-144

1Q.
[Mr Irving]
That is neither here nor there, is it, really? 2A.
[Dr Heinz Peter Longerich]
It was provided by the Jewish communities, so the Jewish 3communities were assuming that, as a kind of solidarity 4with the people who were deported, they had to provide 5them with enough food and tools to survive the first days 6and maybe to build up new homes. I cannot draw from the 7fact that these trains were provided with food and tools, 8I am not able to draw any conclusions as far as the 9motives and aims of the Gestapo was concerned. It refers 10to the Jewish communities in Germany, what they thought it 11was appropriate to do. 12Q.
[Mr Irving]
Yes, but ---- 13A.
[Dr Heinz Peter Longerich]
The SS or the police did not provide the trains with food 14from their own stocks. 15Q.
[Mr Irving]
Yes. I now take you to page 124. That is the other 16message I was referring to, where they are being sent with 17the food and the money and the appliances. 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
This is a message from the SS, is it not, in Bremen to the 20commander of the police in Riga, saying, we are sending 21all these people with this food and with these appliances? 22A.
[Dr Heinz Peter Longerich]
Yes. 23Q.
[Mr Irving]
Is a reasonable inference, reading that, that the people 24in Bremen assumed that they were not just carrying all 25this stuff as camouflage, because they were going to be 26bumped off when they got there? The people in Bremen had

. P-145

1no idea they were going to their deaths? 2A.
[Dr Heinz Peter Longerich]
The Gestapo, you mean? 3Q.
[Mr Irving]
The people who sent this message. 4A.
[Dr Heinz Peter Longerich]
I do not know. I am really cautious to draw this 5conclusion from this document. They are just saying the 6Jews are coming and they are bringing money and tools and 7food with them. I have to see if it survives the internal 8correspondence of the Gestapo in Bremen. I would not 9simply agree. 10Q.
[Mr Irving]
Would not the least perverse interpretation to be put on 11this message be that it is an innocent message from the 12people in Bremen, saying we are sending a train load of a 13thousand people who are members of the chosen race, with 14all their food and appliances, and they are arriving at 15such and such a time, and so on? Any other interpretation 16is pure speculation. 17A.
[Dr Heinz Peter Longerich]
Every interpretation here is I think speculation. The 18money, for instance: Do you think this is money from the 19Gestapo in Bremen to buy food for the Jews in Riga? 20I would think the money is taken from the Jewish community 21and it goes into the pockets of the Gestapo. I see this 22document here and I cannot follow your line of 23interpretation. 24Q.
[Mr Irving]
I am not interpreting it. I am just reading what it says. 25A.
[Dr Heinz Peter Longerich]
Yes. So it says that this train was sent to Riga and did 26they have money and food and tools on the trains? That is

. P-146

1what I can read from the document. 2Q.
[Mr Irving]
Yes. I think, unless your Lordship has another question 3to ask about these decodes, we can move on. 4MR JUSTICE GRAY: Not for me. 5Q.
[Mr Irving]
We now move either onwards or backwards, whichever way you 6look at it, to the 16th July 1941 conference between 7Hitler and Rosenberg on the policing of the Eastern 8territories. Did you use the diary of Otto Brottigan? 9A.
[Dr Heinz Peter Longerich]
I used part of it which is printed in a German edition. 10Q.
[Mr Irving]
Did you not look at my original diary which is in the 11Institute of History? I donated the entire diary to the 12Institute of History. 13A.
[Dr Heinz Peter Longerich]
Yes. I used the one which is printed and commented. 14Q.
[Mr Irving]
I am not sure how much of it is printed but the 15handwritten diary describes the atmosphere of rivalry 16between Rosenberg and Hitler, and Rosenberg coming out 17full of glee because he had got all that he wanted. 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
There is this typical jealous going on at the top level 20inside the hierarchy of Third Reich. 21A.
[Dr Heinz Peter Longerich]
Yes. 22Q.
[Mr Irving]
You agree that in that entire meeting of 16th July 1941 23the word "Jew" was not even mentioned? So it is not very 24important from our point of view, except for establishing 25the hierarchy in occupied Eastern Russia? 26MR JUSTICE GRAY: Where is this in the report, or is it not?

. P-147

1MR IRVING: Page 57, paragraph 15.7. 2A.
[Dr Heinz Peter Longerich]
I am not sure at the moment whether in the entire text the 3name Jew is not mentioned, but I think for me the central 4passage here is this expression of Hitler. 5MR IRVING: Anybody who looks askance? 6A.
[Dr Heinz Peter Longerich]
How would you translate it? 7Q.
[Mr Irving]
Anybody who looks askance can be shot. 8A.
[Dr Heinz Peter Longerich]
Yes. I think this is a category which also would include 9Jews, without particularly referring to them. 10Q.
[Mr Irving]
Yes. You do agree that "der nur schief schaut" does not 11actually refer to somebody looking odd? It is actually 12somebody who is looking out of the corner of his eyes at 13you, or something like that? Anybody suspect? 14A.
[Dr Heinz Peter Longerich]
Anybody suspect, yes. 15Q.
[Mr Irving]
You summarize in paragraph 15.8, rather dangerously and 16adventurously in my view: "With the beginning of the 17massive murder of the Soviet civilian population in the 18summer of 1941, a stage was reached in which these 19statements and similar ones by Hitler could no longer be 20understood as general threats of violence"? 21A.
[Dr Heinz Peter Longerich]
Yes. 22Q.
[Mr Irving]
So we are looking really between the lines, are we there? 23Again, we have nothing specific to point to. 24A.
[Dr Heinz Peter Longerich]
I think, if you look back and look at Hitler's orders and 25his speeches in March 1941, and the fact that he demanded 26the annihilation or the extermination of the Jewish

. P-148

1Bolshevik complex, if you look at the intelligentsia -- of 2course this involved the killing of at least 10,000, 3probably 100,000, people. Then I think one has to take 4this into account if one looks at the way Hitler actually 5used this terminology after these events. I do not know 6whether we have actually reached here the stage where 7I refer to the Einsatzgruppen and their reports back, and 8the fact that these reports were widely circulated, we 9have evidence that Hitler actually has seen them ----. 10Q.
[Mr Irving]
I would be interested. Do you know off the top of your 11head or from your memory what is the evidence that Hitler 12actually read the Einsatzgruppen reports? 13MR JUSTICE GRAY: Let us find it in the report. 14A.
[Dr Heinz Peter Longerich]
I should be cautious here. We have this document from the 151st August 1941. 16MR IRVING: Muller document? 17A.
[Dr Heinz Peter Longerich]
The Muller document, which I erroneously dated 2nd August, 1841, in this report. I cannot find it for the moment. 19Q.
[Mr Irving]
That document does not show he was shown any? 20A.
[Dr Heinz Peter Longerich]
No, you are right. 21MR JUSTICE GRAY: Take this a little bit more slowly. Lets 22find your reference to the Muller document. Is that in 23your second report? 24MR RAMPTON: Yes. 25A.
[Dr Heinz Peter Longerich]
Yes. 26MS ROGERS: Page 26 of 2.

. P-149

1A.
[Dr Heinz Peter Longerich]
You are right, one should be cautious. Is it 26? 2MR JUSTICE GRAY: Are you sure it is page 26. 3MR IRVING: It is in the bundle of documents. 4A.
[Dr Heinz Peter Longerich]
I have it in the report 1, page 57, in the middle of 15.6. 5MR IRVING: Page 50 of the bundle. 6A.
[Dr Heinz Peter Longerich]
I use the wrong date. It is definitely the 1st August. 7It says here: "Dem Fuhrer soll von hier aus lfd Berichte 8unber die Arbeit der Einsatzgruppen im Osten vorgelegt 9weren". In English, the Fuhrer should be presented with 10continuous reports on the work of the Einsatzgruppen in 11the East from here. So it is an intention, yes. But we 12have also other evidence that were not only the 13Eichnesmeldung, which were done on a daily basis, but 14there were also monthly and bimonthly reports about the 15activities of the Einsatzgruppen. We know that these 16reports were widely circulated. They had a distribution 17list with more than a hundred names or institutions on 18it. These monthly reports were widely circulated among 19the different ministries. For example, in the Foreign 20Ministry one of the monthly reports was shown to 22 21people. It is difficult, I think impossible, to argue 22that the result of the activities of the Einsatzgruppen 23could be hidden before anybody, because it was literally, 24I think hundreds of people actually in the official 25capacity have seen these reports. So I think that this is 26enough evidence to say that the intention that Hitler

. P-150

1should see this, that this actually was carried out, 2because it could not be, it was impossible to hide it 3before. On the contrary, it is exactly what he himself 4demanded in these orders. It is about the destruction of 5the Bolshevik Judao empire. That is what he wanted to 6hear and that is why they presented him I think with these 7reports. 8MR JUSTICE GRAY: You say he ordered it and it happened? 9A.
[Dr Heinz Peter Longerich]
Yes. 10MR IRVING: Now I have to ask supplementary questions on that 11of course. You say that these Einsatzgruppen reports had 12lengthy distribution lists. You mentioned 22 names on 13one. 14A.
[Dr Heinz Peter Longerich]
Yes. 15Q.
[Mr Irving]
Was the adjutants officer, the Fuhrer, one of them? 16A.
[Dr Heinz Peter Longerich]
I did not say that 22, the Einsatzgruppen reports, we do 17not have complete distribution lists for every report and 18they vary from report to report. So I do not know. 19Q.
[Mr Irving]
Well let me ask in general terms. On any of the 20distribution lists was there any of Adolf Hitler's 21officers? 22A.
[Dr Heinz Peter Longerich]
We do not have a complete set of distribution lists. 23Q.
[Mr Irving]
Yes. On even one report then? 24A.
[Dr Heinz Peter Longerich]
I have to look to the reports. I cannot say this. 25I found in report No. 128 the Party Chancellery, for 26instance, involved. If you want to argue that these

. P-151

1operations of the Einsatzgruppen were hidden before Hitler 2---- 3Q.
[Mr Irving]
Hidden from? 4A.
[Dr Heinz Peter Longerich]
From Hitler, sorry, then you must argue that Bormann was 5part of this conspiracy because he received a copy, and he 6would not be alarmed and go to Hitler. 7MR RAMPTON: I am sorry. I do not interrupt in the middle of 8an answer -- at least I try not to. Again, I am a bit 9troubled by all of this. I had the transcript reference 10some days ago, weeks ago, I have not got it at the 11moment. My recollection is that Mr Irving accepted in 12cross-examination, first that there was systematic mass 13shootings in the East by the Einsatzgruppen and, secondly, 14that they were approved by Hitler. So where are we going 15I ask myself? 16MR JUSTICE GRAY: Can I just check that because that thought 17had gone through my mind? I was hesitant about it. 18MR RAMPTON: It was early on in the case, almost probably the 19first week. 20MR JUSTICE GRAY: I think I will be able to tell you. 21MR IRVING: I think the answer to that is that there are 22killings and there are killings. 23MR JUSTICE GRAY: I am not sure that is the way it has been 24put. 25MR RAMPTON: I am not going to swear to it, but I think my 26recollection is more or less right.

. P-152

1MR IRVING: I am going to come back to this question. 2MR RAMPTON: I am trying to prevent Mr Irving coming back to 3these questions, because I think it is a waste of the 4court's time and my client's money, and this witness's 5time too. 6MR JUSTICE GRAY: I am not sure, doing the best I can from my 7own notes, that the latter part of what you have just said 8is right. But, if anybody can check on the transcript, it 9is quite an important point. I do not think if I may 10respectfully say, so on your say so I can stop this line 11of cross-examination. If you can pick up a reference? 12MR RAMPTON: No, of course not. 13MR JUSTICE GRAY: Your position now, Mr Irving, and I do not 14suggest it was different before, is that, yes, there were 15these mass shootings going on and there were documents 16floating around reporting them, but you do not accept that 17the reports ever got back to Hitler? 18MR RAMPTON: What I am quite certain about, my Lord ---- 19MR JUSTICE GRAY: Can I have an answer first? Is that right? 20MR IRVING: That is correct, my Lord. That is the position. 21MR JUSTICE GRAY: Although the one we do have for December 42 22says "vorgelegt", you still do not accept that Hitler saw 23it? That is what jogs my memory that I do not think it 24has ever been---- 25MR IRVING: December 29th, 1942 yes, but that is something 26different which we will come to in due course.

. P-153

1MR JUSTICE GRAY: It is the same thing. It is a report of 2shootings by the Einsatzgruppen. 3MR IRVING: My Lord, if you feel I am wasting this witness's 4time, I do hope that your Lordship will tell me. 5MR JUSTICE GRAY: What Mr Rampton is anxious about is that you 6should not waste time by cross-examining on a point which 7you have already conceded. 8MR IRVING: I am very unlikely to do that, my Lord. It is my 9time also. 10MR RAMPTON: I do not agree with that. Certainly it was 11conceded that report No. 51 of 29th December was probably 12seen by Hitler. That is out of the way. That has gone. 13That is 363,000 plus Jewish deaths by shooting. 14MR IRVING: I beg your pardon? That was conceded? 15MR JUSTICE GRAY: I do not think that was conceded. We must 16get the references. 17MR RAMPTON: It was conceded that Hitler probably saw it. 18MR JUSTICE GRAY: No. That is not my recollection. 19MR RAMPTON: I will have to check this and I have to do it 20quickly because otherwise we are going to be here---- 21MR JUSTICE GRAY: Interrupt, if you would, again when you have 22the reference, but I think it is the sort of thing that we 23must have a reference on. Carry on, if you would, 24Mr Irving, unless and until you are interrupted. 25MR IRVING: Very briefly, from your knowledge, if you had seen 26an Einsatzgruppen report which had indicated in the

. P-154

1distribution list that it had been shown to Hitler or to 2Hitler's staff, or to his Adjutants, then you would have 3mentioned it, would you not? 4A.
[Dr Heinz Peter Longerich]
Yes. 5Q.
[Mr Irving]
Can you just say geographically where was the Party 6chancellery situated? 7A.
[Dr Heinz Peter Longerich]
The Party Chancellery, the main office, was in Munich, but 8they had of course a liaison office in Berlin, or wherever 9Hitler was. Bormann was, after he became secretary of the 10Fuhrer, almost constantly a member of Hitler's personal 11entourage. He also made sure that the Party Chancellery 12was always represented in Hitler's entourage if he was not 13able to be present there. 14MR JUSTICE GRAY: You have seen documents where Bormann is on 15the distribution list for these anmeldung? 16A.
[Dr Heinz Peter Longerich]
I have found one. These distribution lists are not 17complete. In 128 it says among 55 copies there is one 18copy going to the Party Chancellery. 19Q.
[Mr Irving]
Would that have been the Munich office? 20A.
[Dr Heinz Peter Longerich]
I think it only said Party Chancellery, and it says Party 21Chancellery in the main well .... 22Q.
[Mr Irving]
Let me ask another specific follow up. On all the copies 23that you have seen, are there any handwritten annotations 24like "has been submitted to the Fuhrer" or anything like 25that? 26A.
[Dr Heinz Peter Longerich]
As far as I have seen, no, there is nothing like that.

. P-155

1Q.
[Mr Irving]
No. Again if you had noticed that, you would have brought 2it to our attention? 3A.
[Dr Heinz Peter Longerich]
Yes. 4Q.
[Mr Irving]
It is not impossible they were shown to Hitler, but we 5have no evidence, is that right? 6A.
[Dr Heinz Peter Longerich]
I would phrase it much stronger. I would think it is 7inconceivable that Hitler was not informed about these 8reports because they were so widely circulated, and there 9was a specific order on 1st August actually that materials 10should be shown to him. 11Q.
[Mr Irving]
What period are you talking about now? Before December 121941 or after December 1941? 13A.
[Dr Heinz Peter Longerich]
We are talking about what? 14Q.
[Mr Irving]
The Einsatzgruppen reports where you say it is 15inconceivable that he was not shown them? 16A.
[Dr Heinz Peter Longerich]
The reports started in June and ended in March '42, and 17I think this would apply to the whole period because this 18letter actually from Muller which says it should be shown 19to him is from the early stages, from 1st August 1941. 20Q.
[Mr Irving]
The fact that the letter from Muller says that the Fuhrer 21wants to be shown them does not necessarily mean to say 22that it was acted upon? 23A.
[Dr Heinz Peter Longerich]
Well, I assume that this was acted upon because, in 24general, orders by Muller were carried out as a very 25efficient head of the secret police. I think ---- 26Q.
[Mr Irving]
One example is that I requested that I should be shown

. P-156

1proof of where this document is and that has not been 2acted upon either? 3MR JUSTICE GRAY: Mr Irving, I think we have gone through this 4enough. I hear what the witness says. He says it is 5inconceivable that Hitler would not have known. 6MR IRVING: One further question on the Muller document. The 7subject of the Muller document is the provision of visual 8materials, is it not? 9A.
[Dr Heinz Peter Longerich]
Yes. Well, it says, in particular, visual material, it 10does not include -- it does not exclude, of course, other 11material. It says [German - document not provided] so 12they should be continuously informed and, in particular, 13he is interested in visual material. 14Q.
[Mr Irving]
Will you read out what the topic line of the telegram is? 15A.
[Dr Heinz Peter Longerich]
Yes, the topic line is [German - document not provided]. 16So the topic line is the visual material. But, of course, 17if you look into this, I mean, if you really look into the 18text here, [German - document not provided] So you can 19read it as it is an established fact that Hitler should be 20on a continuous basis provided with reports, and for this 21purpose he needs, in particular, with the material, so it 22could be that this refers to an older, to an older, 23earlier order, and this is kind of common practice, 24established practice. 25Q.
[Mr Irving]
What were the tasks of the Einsatzgruppen that are 26referred to in this?

. P-157

1A.
[Dr Heinz Peter Longerich]
Well, the tasks were basically the same, I would say, like 2the [German]. So they were, in particular, I mean, they, 3of course, had the explicit orders to execute enemies or 4potential enemies of the Reichs, particularly including 5the Jews, but also they had other tasks, in general, one 6could say intelligence work, for instance, to trace 7documents from the Communist Party, for instance. But 8also you can see from the reports that they were dealing 9with all kind of matters; they were dealing with the 10situation of the churches in the Soviet Union and with the 11food situation, and so on. 12Q.
[Mr Irving]
So these reports were sometimes, what, nine or 10 13paragraphs long of which only one paragraph concerned the 14killing of Jews? 15A.
[Dr Heinz Peter Longerich]
One is, I think, in general, they had a kind of scheme and 16there is one paragraph concerning the fate of Jews and the 17other paragraphs were concerning other issues. 18Q.
[Mr Irving]
So from the Muller telegram of 1st August 1941, is it 19plain what Hitler asked to be shown? 20A.
[Dr Heinz Peter Longerich]
Visual material. 21Q.
[Mr Irving]
Everything, visual -- would there have been visual 22material about the killings? 23A.
[Dr Heinz Peter Longerich]
Well, it refers to posters. We know that there were 24posters, for instance, demanding the Jews had to -- my 25English is running out. 26Q.
[Mr Irving]
"Concentrate"?

. P-158

1A.
[Dr Heinz Peter Longerich]
--- concentrate somewhere a place. It refers to other 2documents; photographs, there were definitely photographs 3of mass executions. So from this, from this list of 4things, I would say, yes. 5Q.
[Mr Irving]
Have you seen any photographs of mass executions in German 6files? 7A.
[Dr Heinz Peter Longerich]
I have not seen photographs of mass executions in German 8files like the Ministry or something like that. 9Q.
[Mr Irving]
Can I take you now to page 62 and we will move forwards 10from there? This is the Goebbels diary entry of December 1112th 1941. We keep coming back against it again. The 12first two and a half lines on page 62: "As concerns the 13Jewish question, the Fuhrer is determined to make a clean 14sweep. He had prophesied to the Jews that if they once 15again brought about a world war they would experience 16their own extermination". That is Goebbels reporting 17Adolf Hitler, is it not, what he said in the speech? 18A.
[Dr Heinz Peter Longerich]
Yes. 19Q.
[Mr Irving]
"This was not just an empty phrase. The World War is 20there, the extermination of Jewry must be the necessary 21consequence. This question must be seen without 22sentimentality. We are not here in order to have sympathy 23with the Jews", and so on. The rest of that paragraph 24could be Hitler speaking, but it could equally well be 25Dr Goebbels' gloss on it, could it not? 26A.
[Dr Heinz Peter Longerich]
I think it is -- I read this as a summary of Hitler's

. P-159

1speech. If you compare the words of Goebbels, the way he 2put it, if you compare it with the speech Frank gave four 3years, four days later in Krakau, you can see that they 4actually use the same words. They both refer to the fact 5that one should not have compassion with them, that they 6both refer to the prophecy. So I think this is a, I would 7interpret it as a summary of Hitler's speech which is 8quite detailed here. 9Q.
[Mr Irving]
As you are a German, Dr Longerich, it is proper to put 10this question to you. Would not that second part of that 11paragraph be in the subjunctive if it was referring to 12Adolf Hitler? 13A.
[Dr Heinz Peter Longerich]
Yes, if one would assume that Goebbels always used the 14subjunctive when he refers to Hitler's speeches, but if 15you look into the Goebbels' diaries, we know that there is 16a mixture of the subjunctive and the present tense. So he 17did not use this in a -- it was not... 18Q.
[Mr Irving]
Consistent? 19A.
[Dr Heinz Peter Longerich]
Consistent, exactly, yes. 20Q.
[Mr Irving]
If it had been subjective, then that would have been a 21clear clue that he was quoting Hitler, would it not? 22A.
[Dr Heinz Peter Longerich]
It would be a clue, yes. 23Q.
[Mr Irving]
So we are not sure either way? 24MR JUSTICE GRAY: When you say subjunctive, you mean reported 25speech? 26A.
[Dr Heinz Peter Longerich]
Yes.

. P-160

1Q.
[Mr Justice Gray]
Well, in German, for reported speech they use the 2subjunctive? 3MR JUSTICE GRAY: Because we do not and that is why I was a bit 4confused. 5MR IRVING: They do in various other languages too, I think the 6Spanish also do and... 7MR RAMPTON: Can I intervene? I have not all the references 8I want, but I suspect this may be sufficient. On day 4 9which is, because I think we can put a stop to all this 10now ---- 11MR JUSTICE GRAY: I think, unfortunately, we have moved past 12it . 13MR RAMPTON: I am so sorry. 14MR JUSTICE GRAY: It is not your fault, but I asked for 15reference. 16MR RAMPTON: It is not my fault, no, because, as a matter of 17fact, I do not have time to read the transcripts in this 18case at the moment. I will have to do that in due course. 1917th January, page 95 -- this reflects and earlier 20concession which I have not presently found -- line 1, 21question by me: "The probability that Hitler saw that 22report", that is report No. 51, "and was, therefore, 23implicated in the murder of all these 363,000 Eastern Jews 24is confirmed, is it not, by a subsequent knowledge of this 25document, by which I mean the Himmler note of the 18th 26December of that year?" Answer by Mr Irving: "Yes, there

. P-161

1is no contention between us on that point". 2 Then if one turns to page 106 on the same day, 3we find your Lordship asking some questions, and at line 419, Mr Irving says: "What authorized, my Lord? The 5killing of Jews, the partisans?" Question by your 6Lordship: "Yes, you accepted that, I thought, a few 7minutes ago". Answer: "The Jews to be liquidated as 8partisans, 16th December, the conversation, yes. If we 9can expand that very meagre note, that skimpy note, into 10that interpretation which I think is a legitimate 11expansion, certainly Hitler sanctioned the killing of the 12Jews on the Eastern Front, all the rest of the Jews, the 13non-German Jews, and that has never been a contention for 14me." 15MR JUSTICE GRAY: Well, that looks fairly clear. 16MR RAMPTON: It is fairly clear. The next day it becomes even 17clearer at page 10, day 5, again it is your Lordship, this 18is line 12 on page 10: "Let us just keep an eye on the 19reality. You did accept yesterday, as I understood it, 20the shooting of Jews and others on the Eastern Front was a 21programme which was systematic and co-ordinated by Berlin 22and Hitler was aware and approved of what was going on?" 23Mr Irving: "The shootings of Russian Jews, my Lord, yes". 24MR JUSTICE GRAY: Russian Jews? 25MR RAMPTON: Yes. That means everybody but the people who were 26coming from Germany. In other words, he is not conceding

. P-162

1that the shooting of the Berlin Jews in Riga was 2authorized, but he is conceding that there was systematic 3mass shooting by the Einsatzgruppen of the Jews in the 4East which was authorized and approved by Hitler. 5MR JUSTICE GRAY: Yes, well again that does look to be fairly 6clear, Mr Irving. This is difficult for you because you 7are in the middle of your cross-examination, but I think 8you must pause and reflect about this because it seems to 9me that Mr Rampton is probably right in saying, although 10I recollect a lot of cross-examination going the other 11way ---- 12MR IRVING: My Lord, I have made a note of the ---- 13MR JUSTICE GRAY: --- Mr Rampton may be right in saying you 14ultimately did concede it. 15MR IRVING: I have made a note of the page number of the 16transcript and I shall certainly attend to it, but I do 17not think this is the time or place to do it. Certainly 18I cannot do it on the hoof like this. 19MR JUSTICE GRAY: No, I think that is right. The problem, of 20course, is that we do not want a lot of cross-examination 21which strictly really is not really relevant because it is 22a point you have conceded, but I think you have really 23moved on beyond the issue of whether Hitler had these 24reports about the shootings on the Eastern Front, have you 25not? 26MR IRVING: It is not a vitally important point.

. P-163

1MR JUSTICE GRAY: Well, leave on one side whether it is 2important. 3MR IRVING: But I am certainly entitled to ask this witness who 4has seen the reports whether he has seen any evidence that 5they were shown to Hitler in detail, and I would certainly 6have to look and see what I had said or m alleged to have 7concede. 8MR JUSTICE GRAY: Yes. 9MR RAMPTON: I just read it out. 10MR JUSTICE GRAY: But, Mr Rampton, he is in the middle of 11cross-examining. I think it is difficult for him to ---- 12MR RAMPTON: I know that, but I am anxious to save time. 13MR JUSTICE GRAY: So I am but ---- 14MR RAMPTON: I really am. 15MR JUSTICE GRAY: --- I think and hope Mr Irving has moved 16beyond now whether Hitler knew through the reports of the 17shooting of Jews in the East. 18MR RAMPTON: I just which I had been able to find this a bit 19more quickly and then I could have saved some time, but 20never mind. 21MR IRVING: Then we would have missed out on some very 22important information which is that there is no evidence 23that Hitler saw the Einsatzgruppen report. 24MR JUSTICE GRAY: Yes, but you have to take the witness's 25answer that it is inconceivable that he did not know which 26would mean that if you did concede the point you were

. P-164

1right to have conceded it. 2MR IRVING: My Lord, with the utmost respect to both yourself 3and to the witness, the fact that something seems 4inconceivable is not evidence or proof. It is interesting 5and has to be put into the scale pans against which has to 6be set the fact that all the evidence is there, the 7documents are now in 55 years later and the evidence is 8still not there. 9MR JUSTICE GRAY: I know you have a lot of other things to do, 10but if you would be good enough to look at those passages 11overnight and perhaps indicate tomorrow morning what your 12considered stance is in relation to Hitler's 13knowledge ---- 14MR IRVING: I will make a little written statement on it. 15MR JUSTICE GRAY: --- of the shootings by the Einsatzgruppen. 16MR RAMPTON: I am a bit cautious about that, if I may say so, 17because what it involves, if Mr Irving should back track 18on what I have just read, or tried to back track, 19Professor Browning has now gone. I cannot bring him back 20without enormous expense and inconvenience from America to 21go through what he would have said if I had known that 22that position was challenged. It means that I have to 23rehearse my quite long cross-examination of Mr Irving on 24this question. I do not believe that in the interests of 25what one might call justice and proportionality that 26Mr Irving ought to be, if I am right about where I got him

. P-165

1to in cross-examination. In the face of the documents and 2what I might call common sense, I do not believe it is 3right that he should be allowed to reconsider his 4position. 5MR JUSTICE GRAY: Let us wait and see what his position finally 6turns out to be, and then we can argue about it if needs 7be. But let me know, please, in the morning and now carry 8on with your cross-examination. 9MR IRVING: I do not think it is an enormously vital point 10actually in the whole Holocaust denial issue one way or 11the other. 12MR JUSTICE GRAY: If it is not a vital point, it may be you 13will keep with your concession. 14MR IRVING: Mr Rampton is yelping before he is hurt actually. 15MR JUSTICE GRAY: Do not let's denigrate his motives. 16MR IRVING: Yes. Page 62, if you look at footnote 157, please, 17you quoted there a document, a wartime document, in the 18last three lines of that footnote there, a very 19confidential information report: "The number of Jews in 20this entire area is estimated at 6 million and in the 21course of the coming year they are going to be brought 22across the Urals or otherwise got rid of"? 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
Does that not also indicate that the primary German 25intention was the geographical movement, dumping them 26across the Urals?

. P-166

1A.
[Dr Heinz Peter Longerich]
Yes, it says ---- 2Q.
[Mr Irving]
Chased across the Urals? 3A.
[Dr Heinz Peter Longerich]
Yes, it says two things. First of all, it is referring to 4the biological eradication of the entirety of Jewry in 5Europe -- sorry, I am confused now. Sorry, those are two 6different documents, yes. You are looking here at this 7confidential report which are the notes of the reporter, 8so this is from a press conference, from a press 9conference, and under the heading "strictly 10confidential". So somebody in the press conference said 11that, you know, a way to solve the problem is to bring 12this estimated 6 million across the Urals. 13Q.
[Mr Irving]
Yes. But does that not indicate that there were two 14things being spoken of at that time, the geographical 15chasing across the Urals, generally spoken of at that 16time? 17A.
[Dr Heinz Peter Longerich]
Yes, I think it is quite ---- 18Q.
[Mr Irving]
"Failing which we are going to have to liquidate them"? 19A.
[Dr Heinz Peter Longerich]
This refers to -- yes, somebody in the press conference 20said in November '41, "It is still a feasible way of 21solving this problem to bring these people over the 22Urals". So that is all I can say. 23Q.
[Mr Irving]
It is a press conference by Rosenberg, right? 24A.
[Dr Heinz Peter Longerich]
Yes. 25Q.
[Mr Irving]
It is not a vitally important point, but there does 26appear, even at that time, to have been a degree of

. P-167

1uncertainty as to what was going to happen? 2A.
[Dr Heinz Peter Longerich]
Yes, but one should then also, if one speaks about this 3press conference, one should not leave out the words, you 4know, Rosenberg's words, "biological eradication of the 5entirety of Jewry". 6Q.
[Mr Irving]
They are both second-hand reporting, are they not? One is 7by the [German]? 8A.
[Dr Heinz Peter Longerich]
Yes. 9Q.
[Mr Irving]
Who is that? I forget who that was, Rosenberg, but, 10anyway, it is a second-hand report, is it not? 11A.
[Dr Heinz Peter Longerich]
Yes. 12Q.
[Mr Irving]
Over the page, of course, page 63, we have something that 13is very first-hand. This is the vital Heinrich Himmler 14note of 18th December 1941. 15A.
[Dr Heinz Peter Longerich]
Yes. 16Q.
[Mr Irving]
You probably know what I am going to ask you, if you have 17the phrase Judenfrager als partisan and ausurotten, what 18does that mean? How would you translate that into 19English? Als partisan and ausurotten? 20A.
[Dr Heinz Peter Longerich]
Well, to be extirpated as partisans. 21Q.
[Mr Irving]
Yes. I think there is no question in this case that it 22has a homicidal meaning, does it not? 23A.
[Dr Heinz Peter Longerich]
Yes. 24Q.
[Mr Irving]
And what does one normally do with partisans in warfare? 25Are they shot? 26A.
[Dr Heinz Peter Longerich]
I do not know what one normally does, but from the -- the

. P-168

1orders were here clear. I mean, I refer to this orders at 2the beginning. The orders here were clear that a civilian 3who would, you know, actually -- a civilian who ---- 4Q.
[Mr Irving]
"Who takes guns up"? 5A.
[Dr Heinz Peter Longerich]
--- who takes guns up, yes, would be shot on the spot. 6Q.
[Mr Irving]
That is the basic laws of war, the Frank tireur(?) are 7shot. The Americans did it, we did it. 8A.
[Dr Heinz Peter Longerich]
Well, I only can answer this question as far as the German 9Army and the war on the East is concerned. It was, you 10know ---- 11Q.
[Mr Irving]
If it had said the partisan and ausrottung, that would 12have been to be shot like partisans ---- 13A.
[Dr Heinz Peter Longerich]
Yes, it would be different. 14Q.
[Mr Irving]
That would have been a totally different meaning, would it 15not? 16A.
[Dr Heinz Peter Longerich]
It would be different, yes. 17Q.
[Mr Irving]
Does the meaning of that sentence as it stands imply that 18these were Jewish partisans who were to be shot as 19partisans? 20A.
[Dr Heinz Peter Longerich]
No. "Juden to be extirpated as partisans". It does not 21mean that only Jews have recognized as partisans were 22shot, they are just Jews were shot as partisans. 23MR JUSTICE GRAY: "As if they were partisans", that is what it 24comes to? 25A.
[Dr Heinz Peter Longerich]
Yes. 26Q.
[Mr Justice Gray]
That is your evidence?

. P-169

1A.
[Dr Heinz Peter Longerich]
Yes. 2MR IRVING: Although it does say "as partisans" and not "like 3partisans", if I can put it in English. I do not want to 4hang that on the big bell, as you say in German, but there 5is a difference between the two words "als" and "wie", is 6there not? 7MR JUSTICE GRAY: Yes, but I think the witness is not accepting 8your interpretation, Mr Irving. 9MR IRVING: Well, the translation is specific, but he may not 10accept the interpretation of it, of course, the 11conclusions from it. Paragraph 17.7, you have Adolf 12Hitler, on the fifth line of that, on 30th January 1942, 13saying that it is clear the war can only end with either 14the Aryan peoples being extirpated or the Jews 15disappearing from Europe", "Das Judentum aus Europa 16verschwindet". That again implies a geographical 17solution, does it not? This is 10 days after the Wannsee 18conference. 19A.
[Dr Heinz Peter Longerich]
Well, "das Judentum aus Europa verschwindet", I think that 20this expression, "aus Europa verschwindet", could be seen 21as a camouflage language that actually disappeared from 22the German, from the area under German control, by, you 23know, anyhow. There was actually no chance how, you know, 246 million Jews could disappear at this stage from the 25German, from the territory under German control. 26Q.
[Mr Irving]
As you point out just three days earlier in one of the

. P-170

1table talks, this is now the following page, the second 2indented paragraph: "The Jew must get out of Europe. The 3best would be if they went to Russia! I have no sympathy 4with the Jews. They will always remain an element which 5stir up the peoples against one another". Again he is 6talking of a geographical solution even in private, to his 7own private staff? So why would camouflage be necessary 8there? 9A.
[Dr Heinz Peter Longerich]
Well, when you refer to the so-called [German], the table 10talks, one has to take into account that the table talks, 11you know, there were various people present on the table, 12so you could not, you cannot just assume that this is what 13Hitler really thought, that this really, you know, you are 14getting deep insight into his real world. This is always 15addressed to all kinds of people who were just present 16there. So he would be very cautious to speak about his 17real intentions, as far as the Jews are concerned. So 18I would hesitate to draw this conclusion from that. 19Q.
[Mr Irving]
He never had any outsiders at these table talks, did he? 20They were always members of his private staff. 21A.
[Dr Heinz Peter Longerich]
Yes, but the members of his private staff, I mean, for 22instance, his secretary and others were not to, you know, 23Hitler has very specific rules about keeping secrecies and 24they were not, you know, just because they were his 25coworkers, they were not allowed to share all the secrets 26with him.

. P-171

1Q.
[Mr Irving]
But on occasion in his table talks he speaks pretty 2tough. He talks pretty violent language, does he not, in 3the table talk? 4A.
[Dr Heinz Peter Longerich]
Yes, that is true, but I do not think that the table talks 5are the best, the ideal source to find out, you know, what 6was really going on in Hitler's mind because Hitler was 7very careful, particularly as far as the Holocaust is 8concerned, very careful what he was saying there. 9Q.
[Mr Irving]
Well, the only justification for saying that kind of 10thing, of course, is if you have anything explicit 11anywhere else and there is not, is there? Is it not 12possible that he is just saying what is in the table talk 13and in Goebbels' diary and elsewhere is an accurate 14reflection of what Hitler really knew? Is that not a more 15logical explanation? 16A.
[Dr Heinz Peter Longerich]
Well, I think the Goebbels diaries are different from the 17table talks but I ---- 18Q.
[Mr Irving]
Can I take you to paragraph 18.7 which is two pages later, 19page 56? The last paragraph there, you do not quote it in 20full, but this is the paragraph, my Lord, that we were 21looking at yesterday which is ---- 22MR JUSTICE GRAY: Yes, I remember. 23MR IRVING: --- the deportation to Siberia. 24MR JUSTICE GRAY: Central Africa too. 25MR IRVING: Central Africa, yes. Is that also more camouflage 26and even with Dr Goebbels sitting there who knows very

. P-172

1well what is going on or suspects what is going on? 2A.
[Dr Heinz Peter Longerich]
Yes, you know, if we look at the situation what was going 3on in April '42, we know that probably three quarter of a 4million or one million Jews in the Soviet Union were 5shot. They had started to systematically kill Jewish 6women and children in Serbia. They had opened the -- if 7this is the right way to say it -- extermination camp in 8Chelmo in December, they had just opened the extermination 9camp in Belzec and were carrying out mass extermination 10there. So one has to take this into account. 11 Really, I have difficulties, I have to say, to 12find, you know, an easy answer to this document because, I 13mean, they are in the middle of mass extermination and 14Goebbels is quite aware of that, and they are still 15talking about the idea that they could force the Jews out 16of Europe. I find this really difficult to explain. 17Q.
[Mr Irving]
Can you not see any possible explanation? 18A.
[Dr Heinz Peter Longerich]
Possible explanation ---- 19Q.
[Mr Irving]
That Hitler did not know? 20A.
[Dr Heinz Peter Longerich]
The possible explanation would be that they just used 21among themselves this kind of camouflage language because 22they did not, they did not -- I mean, I have no trace, no 23evidence, that they spoke among themselves really about, 24"We are going, we are about to kill 6 million people. We 25are going to kill men, women, children, everybody", so 26they would use this kind of, this kind of language among

. P-173

1themselves, and, yes, that is the explanation which seems 2most plausible to me. 3Q.
[Mr Irving]
They were in a state of denial then, they were doing these 4things but pretending they were not? 5A.
[Dr Heinz Peter Longerich]
Among themselves, I think, you know, they were in a way or 6Hitler was in this way using double standards. He was, 7I think, I am convinced that he was quite aware what was 8happening ---- 9Q.
[Mr Irving]
You keep saying that. 10A.
[Dr Heinz Peter Longerich]
--- but among one of his best friends, so among themselves 11they would use a different language, they would not speak 12about, they would not say, you know, "We are actually 13killing so many children per month". They would just ---- 14MR JUSTICE GRAY: But if he knew, supposing, assuming that 15Hitler knew all about the death camps and all the rest of 16it, what puzzles me a little bit about this camouflage 17theory is I do not quite see why it was necessary to talk 18about the Jews at all. Would you not keep your mouth shut 19rather than have this pantomime going on? 20A.
[Dr Heinz Peter Longerich]
Well, if you look into the conversation between, you know, 21Goebbels and Hitler, this was a constant, you know, a 22topic which was constantly raised among them. It was a 23kind of tour de raison. They would cover every 24interesting, evert aspect which looked interesting from 25their point of view. They would speak about the war, the 26conduct of war, they would speak about the -- the

. P-174

1situation, the foreign policy, and they would cover this 2topic, the Jews, the Jewish question, and they would -- 3this is my reading of this -- they would encourage 4themselves, "Yes, they are dangerous, we have to do 5something against them, we have to carry on with our 6policy". 7Q.
[Mr Justice Gray]
That does not really explain why you then talk about it in 8camouflage language at the table talk; why not keep your 9mouth shut? 10A.
[Dr Heinz Peter Longerich]
I think, if you remember the speech Himmler gave on 4th 11October, he said, "Well, actually we do not speak among 12ourselves about this. It is a question of taste. We do 13not speak about this". It is a history which has not been 14written which will never be written, and I think they went 15so far that even among themselves they would, you know, 16hesitate at this wonderful day in spring 1942 actually to 17say, "Yes, actually we are killing them". So that is the 18best explanation I can offer. It is clear from the 19documents that it stood in clear contrast to what they 20were doing. 21MR IRVING: Dr Longerich, in the Institute have you read the 22memorandum by Karl Wolf who was Himmler's adjutant and 23liaison officer to Himmler for sometime? 24A.
[Dr Heinz Peter Longerich]
Which? 25Q.
[Mr Irving]
There were several handwritten memoirs by him, SS General 26Karl Wolf. Can I put to you one passage from them which

. P-175

1might help to explain this kind of conversation and ask 2you if you remember it? 3A.
[Dr Heinz Peter Longerich]
Yes. 4Q.
[Mr Irving]
Where Karl Wolf says: "I am certain that Hitler did not 5know what was going on. I think it was kept from him. We 6had to keep the Messiah of the coming 2,000 years clean of 7this matter"? 8A.
[Dr Heinz Peter Longerich]
Well, I think one has to again ---- 9Q.
[Mr Irving]
Do you remember that passage? 10A.
[Dr Heinz Peter Longerich]
--- I have to look at the document. I do no think -- they 11are not published. I do not think they are accessible to 12everybody. 13Q.
[Mr Irving]
I have seen them. 14A.
[Dr Heinz Peter Longerich]
Yes, but I think ---- 15Q.
[Mr Irving]
And they are in my discovery. 16A.
[Dr Heinz Peter Longerich]
--- as far as I am aware of, this is not a source which is 17accessible to every historian. They are not in a public 18archive on a library. If we, I mean, I would be happy to 19see them, but I think I would have to be in front of ---- 20MR JUSTICE GRAY: I think that is fair. It is very difficult 21to comment on an extract like that. 22MR IRVING: But can I just put it this way? Is the suggestion 23that Karl Wolff or the SS were anxious to do the dirty 24deed without getting Hitler, the Messiah of the coming 252,000 years implicated himself, would that explain how 26this situation would arise?

. P-176

1A.
[Dr Heinz Peter Longerich]
Wolff was sentenced in, was it, 199 -- 1965 or something, 2I think he was sentenced to a 15-year prison sentence, 3I think, so, really, he was -- his main occupation after 4the war was, actually his main problem after the war was 5to distance himself from these murderous actions. He did 6not want to spend the rest of his life in prison, so I 7would be very, very cautious to take this as face value, 8to, you know, what he knew, what Hitler knew. The whole 9attitude of Wolf is to say, "I was just a military man. 10I had nothing to do with these things. This was even not 11mentioned in my presence". 12 So I am really, first of all, I have not seen 13the document, but really, in general, would be very, very 14hesitant to draw -- to follow him. 15Q.
[Mr Irving]
Would that not explain Heinreich Himmler's later remark on 16October 4th 1943, that this is a matter about which we 17never talk, if they wanted to keep it away from Hitler, 18would that not be the explanation? 19A.
[Dr Heinz Peter Longerich]
I do not think he said in the speech, "We kept it away 20from Hitler". He says, basically, "We do not mention 21it" ---- 22Q.
[Mr Irving]
Among others? 23A.
[Dr Heinz Peter Longerich]
" --- among ourselves". If you go to the Himmler speech 24and if you do it in a more systematic way, you can see 25that actually he refers to higher orders which were given 26to him. So I think you can link this speech with Hitler.

. P-177

1MR JUSTICE GRAY: That is the awful responsibility? 2A.
[Dr Heinz Peter Longerich]
Yes, for instance. 3MR IRVING: On page 66 near the end of that, five or six lines 4up, you say: "Even talking to his closest associates 5Hitler avoided speaking openly on mass killing". This is 6your kind of gloss you put on paragraphs like that, that 7you are trying to explain how it is that in the documents, 8contemporary documents there are these baffling passages, 9if I can use the word "baffling"? 10A.
[Dr Heinz Peter Longerich]
No. I have only seen one, this is the one in 1985, and 11I think we do not have many examples of that. 12Q.
[Mr Irving]
On 69 there is I think the one you were just referring to 13in paragraph 19.3, July 28th 1942, Himmler wrote to 14Gottlegberger, an SS General, saying: "The Fuhrer has 15placed on my shoulders the implementation of this very 16difficult order and the responsibility cannot be taken 17away from me in any case." What order was that? 18A.
[Dr Heinz Peter Longerich]
That is left out in the translation unfortunately. 19One had to add the first sentence in German. The first 20sentence of this quotation is: "The occupied Eastern 21territories will be free of Jews", and then he goes on: 22"The Fuhrer placed on my shoulders the implementation of 23this very difficult order." 24 This is in July 1942. I think that quite 25clearly Hitler gave Himmler the order to kill every Jew in 26the occupied Eastern territories, and Himmler saw this a

. P-178

1particularly unpleasant and difficult task, but he was of 2course, as obedient as he was, prepared to carry on. So 3this is my reading of the document. 4Q.
[Mr Irving]
Of course the document does not reply to another letter 5referring to the killing of the Jews, does it? 6A.
[Dr Heinz Peter Longerich]
No. It is mentioned in a letter to Berger, but I think 7this is one of the clearest statements we have. 8Q.
[Mr Irving]
It is indeed very clear. 9A.
[Dr Heinz Peter Longerich]
"The occupied Eastern territories will be free of Jews", 10it is, "The Fuhrer placed on my shoulders the 11implementation of this very difficult order, the 12responsibility cannot be taken away from me in any case". 13MR JUSTICE GRAY: "Detesbefehl" must refer back, you would say, 14to making the Oskabitte free of Jews. 15A.
[Dr Heinz Peter Longerich]
Yes, I explain this just for the minute. In the 16translation I left unfortunately out the first sentence. 17Q.
[Mr Justice Gray]
I follow that. 18A.
[Dr Heinz Peter Longerich]
And the first sentence is: "The occupied Eastern 19territories will be free of Jews". It is in the German 20text but not in the English text. 21MR RAMPTON: My Lord, the full text, in case anybody thinks it 22is important, which it may well be, is in the new bundle N 23whatever it is. 24MR JUSTICE GRAY: You mean the words before the omitted words? 25MR RAMPTON: Yes. There are two paragraphs and this is a 26microfilm.

. P-179

1MR JUSTICE GRAY: I think this is worth looking at. 2MR RAMPTON: I think it might be important for this witness in 3particular. 261, my Lord, we have reproduced 4Dr Longerich's short English translation of two sentences, 5and, as he says, defective translation of two sentences. 6MR JUSTICE GRAY: Not defective but deficient. 7MR RAMPTON: No, but the whole of the German text is in a 8microfilm copy on the right-hand side. 9MR IRVING: My Lord, just for the record, I have no objection 10to any of the extracts this witness has made. He has left 11nothing out of any importance. 12MR JUSTICE GRAY: No, I accept that. Should we just have a 13look. Did you say 261, Mr Rampton? 14A.
[Dr Heinz Peter Longerich]
261, yes. 15MR RAMPTON: 261 I think I was told to say. 16MR JUSTICE GRAY: I see, it is paragraph 1. 17MR RAMPTON: It is in paragraph 1. It is the second part of 18paragraph 1. 19MR JUSTICE GRAY: Can you just translate? 20A.
[Dr Heinz Peter Longerich]
The whole thing? 21Q.
[Mr Justice Gray]
The first sentence on paragraph 1. 22MR IRVING: Yes: "I urgently ask you not to have any ordinance 23about the concept of the word "Jew" issued. With all 24these stupid determinations we are just tying our own 25hands. The occupied Eastern territories will be free of 26the Jews. The execution of this very difficult order has

. P-180

1been placed on my shoulders by the Fuhrer. So nobody can 2take that responsibility from me." 3A.
[Dr Heinz Peter Longerich]
I would agree. 4MR JUSTICE GRAY: So there has been some sort squabbling about 5what comes within the definition of a "Jew". 6MR IRVING: Who is a Jew. 7A.
[Dr Heinz Peter Longerich]
He did not want them to issue a regulation about the 8definition of the Jew because it was not necessary any 9more, because the problem has ---- 10MR JUSTICE GRAY: And Himmler is saying: "I have been ordered 11to sort the problem out by getting rid of the Jews and get 12on with it." 13A.
[Dr Heinz Peter Longerich]
Yes. 14MR IRVING: Yes. So the question which arises from that, 15Dr Longerich, is does this not fit in with the scenario 16that I suggested, that Hitler had said to Himmler: "You do 17the job, keep me out of it, I will keep people off your 18back, just get on with it, but don't bother me with it"? 19A.
[Dr Heinz Peter Longerich]
Well, it says here, this is my reading, that Hitler has 20given Himmler the order that the occupied territories 21shall be free of Jews. So which way this happened I do 22not know, whether this was ---- 23Q.
[Mr Irving]
So, "I can do what I want and buzz off"? 24A.
[Dr Heinz Peter Longerich]
Yes, you can speculate about this, but I do not have the 25minutes of the conversation between Hitler and Himmler. 26It could be a very explicit order, a very clear order. It

. P-181

1could also be something general. Why should I speculate 2about it? I do not have the text in front of me. 3Q.
[Mr Irving]
Now let me take you ahead to page 72, please, the first 4indented paragraph, and we get a little bit closer to what 5I am asking for. This is the second closing speech on 6October 6th 1943. 7A.
[Dr Heinz Peter Longerich]
Yes. 8Q.
[Mr Irving]
"I ask you that which I say to you in this circle be 9really only heard and not ever discussed. We were faced 10with the question "What about the women and children?" 11I took the decision to find a very clear solution to this 12problem here too." "I took the decision". Now is Himmler 13saying Hitler took the decision or is Himmler saying "I, 14Himmler, took the decision"? 15A.
[Dr Heinz Peter Longerich]
Yes, you answered the question yourself I think. 16Q.
[Mr Irving]
Yes, and that is pretty clear, is it not? 17A.
[Dr Heinz Peter Longerich]
Yes, but he did not say in this, he does not say in this 18speech that he took the decision without having the 19consent of Hitler. 20Q.
[Mr Irving]
Oh, yes, he has been given the overall blank cheque by 21Hitler, has he not? 22A.
[Dr Heinz Peter Longerich]
Yes, I think it is fair to argue -- I think he is 23referring here to the extension of the shootings in the 24Soviet Union, the extension of the shootings to women and 25children, which happened between the end of July 1941, end 26of October 1941, where actually the various killing units

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1extended their shootings to include in the mass executions 2also women and children, shot also women and children. 3I think, as far as I am concerned, as I tried to 4reconstruct as precisely as possible the decision-making 5process, that clearly there is some kind of initiative 6coming from Himmler, but I have no doubts that this was in 7full consent and that Himmler acted under the -- that 8Himmler was convinced, deeply convinced that he acted with 9full consent of Hitler. I have no doubt about that. Also 10in this he says for the organization which had to execute 11this task. I think also this organization, it could be 12read as a reference to a higher order, an order which was 13given from, well, somebody above Himmler. 14Q.
[Mr Irving]
I strongly disagree, Dr Longerich. If he says, "I am the 15one who took the decision that the women and children had 16to be killed too", and that the people who had to do this 17job, it was very unpleasant for them, there can be no 18doubt at all what job he is talking about and who gave the 19order, he Himmler? 20A.
[Dr Heinz Peter Longerich]
Well, I think you can read this sentence, it also can be 21read as that the SS, a reference to a higher order, but 22I cannot dispute, I do not want to dispute, that Hitler is 23referring here to his own initiative, but I on the other 24hand, looking at the whole history in 1941, in the second 25half of 1941, I have no doubts that he came to this 26conclusion with the deep conviction that he acted

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1according to the wishes of Hitler. I mean this idea to 2separate in a way Himmler from Hitler and to insinuate 3that Himmler would have carried out this operation behind 4Hitler's back, I really have to say that this looks quite 5absurd to me, because if you look at Himmler's 6personality, for instance, Himmler was obedient, he was as 7loyal as he could be to Hitler. He was an anxious 8person. I think the whole personality, Himmler can only 9be explained as somebody who, it is really a remarkable 10example of somebody who really did the utmost to carry out 11the wishes of Hitler. The whole died of idea that this 12whole operation, this enormous operation, killing 13operation of 6 million people could be started and could 14be carried out on a large scale with implications, you 15know, transportation, the building of extermination camps, 16the involvement of 10,000 people who had to carry out this 17programme and the ramifications as far as the foreign 18policy was concerned, the policy towards the German Allies 19was concerned, all this, that this could be carried out by 20Hitler not asking, not being sure that he actually acted, 21you know, on Hitler's, according to Hitler's wishes, this 22whole notion seems absolutely, I hate to say this in a 23very strong way, absurd. I think we cannot build this 24case on three or four documents you find in the archives. 25I think you have to look at the whole system. You have to 26look at the relationship between Hitler and Himmler. You

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1have to look at the way this was carried out. I simply 2cannot follow this line of argumentation. 3Q.
[Mr Irving]
So Himmler was a weak man? 4A.
[Dr Heinz Peter Longerich]
In a way Himmler had -- in a way Himmler had some 5weaknesses. You are quite familiar, you wrote biographies 6about the leading Nazis, and you I think are quite aware 7of the fact where are his weakness. 8Q.
[Mr Irving]
Himmler's brother Gebhardt told me that Heinreich was such 9a coward that he would never have done this without 10Hitler's orders. So he backs you. But the fact remains 11that we are faced with these baffling documents, are we 12not? 13A.
[Dr Heinz Peter Longerich]
Yes. The question is now whether these documents are 14really sufficient enough to prove the case that the 15Holocaust was carried out by Himmler behind Hitler's back, 16you know, without his knowledge, without his approval. 17Generally speaking, my impression is that it is impossible 18to prove this case. 19Q.
[Mr Irving]
You mention the transportation, that this could not have 20been done without Hitler's orders? 21A.
[Dr Heinz Peter Longerich]
All this, not only transportation but the whole magnitude 22of this operation. 23Q.
[Mr Irving]
But Himmler referred specifically to the fact that this 24movement of the Jews from the West to East is going to 25proceed stage by stage, is the Fuhrer's orders, September 261942 I think is the document?

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1A.
[Dr Heinz Peter Longerich]
Yes. 2Q.
[Mr Irving]
So that was covered by Hitler's orders, the actual 3transportation movement. That was clearly covered by 4Hitler's orders? 5A.
[Dr Heinz Peter Longerich]
Yes, but all the over -- I can accept that, but it is not 6only the transportation. It is the involvement of 10,000 7people in police units, in SS units. 8MR JUSTICE GRAY: The whole. You do not need to spell it out? 9A.
[Dr Heinz Peter Longerich]
The whole operation. 10MR JUSTICE GRAY: One can imagine how logistically complicated 11it was. 12A.
[Dr Heinz Peter Longerich]
The Holocaust became known in 1942 to the Western world, 13and of course it was used in the Allied propaganda, for 14instance, they dropped leaflets on Germany, and so on. So 15the whole idea that this process could be kept as a secret 16when, you know, 22 officials in the Foreign Ministry alone 17read one of the activity reports of 1941 which quite 18clearly states that thousands of people are shot, and 22 19diplomats were officially allowed to read this. Then to 20argue that this was done behind Hitler's back, it seems to 21me it defies reason. 22MR JUSTICE GRAY: Yes. I have your very clear and full answer 23on that. Mr Irving, I do not know whether you are going 24to move on now? 25MR IRVING: I have now reached effectively my planning for the 26first report. I will conclude the cross-examination on

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1the second report tomorrow, and then I shall be finished 2with Dr Longerich tomorrow, if I may. 3MR JUSTICE GRAY: Yes, you are really saying you would rather 4break off now? 5MR IRVING: Quite simply because we did zip through the 6glossary. I think it does fall naturally in two stages. 7MR JUSTICE GRAY: I am not sure about that, but if you say you 8would like to break off now then I am perfectly happy with 9that. Can we just see where we are going from here. 10Mr Rampton, are we expecting to have any other witness on 11Thursday? I suppose that depends on Mr Irving. 12MR RAMPTON: No. I can start re-cross-examination Mr Irving on 13Thursday, if we go short with Dr Longerich. If not I will 14do that on Monday. I am expecting Professor Funke to be 15here on Tuesday. 16MR JUSTICE GRAY: Have you got a whole day's further 17cross-examination, do you think? 18MR RAMPTON: Probably. 19MR JUSTICE GRAY: I am not surprised. 20MR RAMPTON: Probably, because I have not done the political 21association. Considering the volume of material there is, 22I am going to keep it short, but it is still bound to take 23a bit of time. 24MR IRVING: My Lord, ought I to question this witness about the 25Schlegelberger document which he has not referred it in 26his report?

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1MR JUSTICE GRAY: He has not, you are quite right, and 2I personally think there is absolutely no need, because if 3there is one topic that has been investigated exhaustively 4it is certainly that one. 5MR IRVING: I do not want to be criticised for not having done 6so. 7MR JUSTICE GRAY: I will not criticise you and I do not think 8Mr Rampton will either. 9MR IRVING: Your Lordship is aware I attach great importance to 10it. 11MR JUSTICE GRAY: Yes, I realize you do. 12MR RAMPTON: I would point out, therefore, that it is likely 13that I will place reliance on what Dr Longerich has 14already said about that, which is that, in effect, he 15thinks it is a document of no historical significance. 16MR IRVING: Yes. 17MR JUSTICE GRAY: Yes. The trouble is you cannot nibble at 18these issues. I hope Mr Irving will not take that as an 19invitation to open the whole issue. 20MR RAMPTON: No, but it is only fair that I should say that. 21I would use as corroboration for reliance on that what 22Professor Evans has said about it. 23MR JUSTICE GRAY: Professor Evans? 24MR RAMPTON: Yes. 25MR IRVING: If Professor Evans wishes to have a chance to 26amplify the reason why he considers it to be insignificant

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1or less significant than do I, then this would be the 2opportunity. 3MR JUSTICE GRAY: I think the answer to that is that he will 4not want to. 5MR RAMPTON: He is in Cambridge. 6MR JUSTICE GRAY: I think you meant Dr Longerich, did you not? 7MR IRVING: That was the correct inference, yes. 8MR JUSTICE GRAY: I am sure he will not want to, but Mr Rampton 9is entitled to rely on his commentary about it. Since 10I know so clearly what the issues are each way on it, 11I really see very little benefit to be derived from going 12through all the points all over again. 13MR IRVING: I have no desire to. 14MR JUSTICE GRAY: If you want to I am not stopping you. 15MR IRVING: But I thought it would only be fair in view of the 16fact that he did express that negative opinion on it, if 17he wished to have the opportunity to amplify on that that 18he should, but if he does not so ---- 19MR JUSTICE GRAY: Just so it is clear, I am not for a moment 20stopping you from cross-examining fully on your reasons 21for saying why the Schlegelberger memorandum is a very 22important document, but I will not hold it against you 23that you did not cross-examine if you do not. I want to 24be absolutely clear what my position on that is. 25MR IRVING: If your Lordship will not then I shall not. 26MR JUSTICE GRAY: Good. I think that is a sensible outcome,

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1because otherwise it is just a waste of time. 2MR RAMPTON: Can I give your Lordship two more references to 3close the day. 4MR JUSTICE GRAY: Yes. 5MR RAMPTON: Day 2, page 262, lines 11 to 17, I will read it 6out for Mr Irving's benefit so he knows exactly. 7MR JUSTICE GRAY: Of what? 8MR RAMPTON: Of my cross-examination in the transcript. 9MR JUSTICE GRAY: Day 2? 10MR RAMPTON: Yes, page 262. Again I am afraid for some reason 11best known, perhaps it is that I merely lay the ground and 12all the bright questions seem to be asked by your 13Lordship. Maybe your Lordship has a better facility for 14getting straight answers, I do not know. Anyway, page 15262, line 11, Mr Justice Gray asks Mr Irving: 16 "Do you accept that means," this is about report 17No. 51, "since it is addressed to the Fuhrer that it was 18shown to him?" 19 Answer: "On a high probability, yes, my Lord. 20I would have accepted that as being evidence that it had 21probably been shown to Hitler, but I would also draw 22attention to one, two or three details, if I may, since we 23are looking at the document." 24 Then bottom of page 264, which is on the same 25physical sheet of paper, line 23, again your Lordship is 26asking the question:

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1 "To be asked what you think this would have 2conveyed to Hitler, which is I think what Mr Rampton was 3asking?" 4 Answer: "Firstly, I accept the document was in 5all probability shown to Hitler. Secondly, I think in all 6probability he paid no attention to it, the reason being 7the date, the height of the Stalingrad crisis". 8 If there is going to be a retreat from that 9position, it is going to have to have, in submission, 10quite a good reason. 11MR IRVING: Well, my response is that I think documents are 12often shown to learned counsel which learned counsel 13sometimes pay no attention to. I think Mr Carmen is an 14example of that. 15MR RAMPTON: I am not Mr Carmen for one thing, and I shall not 16say what I feel about that. 17MR IRVING: Also your Lordship will remember ---- 18MR JUSTICE GRAY: Let Mr Rampton tell us more about it. 19MR RAMPTON: For another thing, that is only to say that it 20seems that that concession, and I advisedly use that word, 21seems to remain in place. 22MR JUSTICE GRAY: Indeed it is fortified, because Mr Irving is 23there saying that, all right, it may have been shown to 24Hitler, but he paid no attention to it, well, that is 25almost the same as saying it was not shown to him. But he 26goes done in day 4 and 5 in the passages that you have

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1referred to I think to accept that Hitler knew and 2approved. 3MR RAMPTON: Yes, knew about the systematic mass shootings in 4the East. 5MR IRVING: Your Lordship remember that I produced evidence to 6you a day or two later showing that on precisely that day 7or the day before one document of exactly the same nature 8was shown to Hitler on two successive days, submitted to 9him and obviously not read by him. 10MR JUSTICE GRAY: Yes. I suspect the position will emerge that 11you have slightly shifted your ground backwards and 12forwards in the course of your answers to Mr Rampton. 13MR IRVING: It is highly possible that one learns as one goes 14along, and one would be incorrigible if one did not. 15MR JUSTICE GRAY: I will not comment about that, but you have 16now put your case actually in considerable detail to 17Dr Longerich and we have now had his answers. 18MR IRVING: Yes. 19MR JUSTICE GRAY: So tell me what your final stance is, because 20I would like to know, but the evidence is all in now. 21MR RAMPTON: I would like to know too. 22MR JUSTICE GRAY: So 10.30 tomorrow morning. 23< (The witness withdrew)24(The court adjourned until the following day)2526